Privacy policy
The following Privacy Policy describes how We, Posy (PT Pintar Ventura Pertama and its affiliates, "We", "Our", "Ours", "Us" or "Posy") collect, store, use, process, control, transfer, disclose and protect your Personal Information This Privacy Policy applies to all users of Our application, website (http://posy.co.id ), services, or products ("Applications"), unless set out in a separate privacy policy. Please read this Privacy Policy carefully to ensure that you understand how our data is processed. Unless otherwise defined, all capitalized terms used in this Privacy Policy have the same meaning as those stated in the Posy Application Terms of Use. This Privacy Policy encompass the following:
1. Personal Information We collect
2. Use of Personal Information We collect
3. Provision of Personal Information We collect;
4. Storage of Personal Information;
5. Access and correction of Personal Information
6. Cross-border Transfer Data
7. Security of your Personal Information
8. Changes to this Privacy Policy
9. Recognition and approval
10. Marketing and promotional materials
11. Anonymous data
12. Third party platforms
13. Severability
14. How to contact us

1.PERSONAL INFORMATION WE COLLECT We collect information that identifies or can be used to identify, contact or locate the person or device to whom the information is associated ("Personal Information"). Personal Information includes, but not limited to, name, address, telephone number, e-mail address, bank account, gender, identity card identities (including Indonesian Identity Card (E-KTP), driving license (SIM) or passport) or other government-issued identity, photograph, nationality, telephone numbers of users and non-users of Our Platform contained in your mobile phone contact list, health data, related financial information, and biometric information (including but not limited to face recognition). Furthermore, for other information, such as a personal profile, and/or unique identified number, which is associated or combined with Personal Information, such information shall also considered as Personal Information. The Personal Information We collect may be provided by you directly or by a third party (for example: when you register or use the Application, when you contact Our customer service, or vice versa when you provide Personal Information to Us). We may collect information in various forms and purposes (including purposes permitted under applicable laws and regulations).

Information We collect from you or your mobile device directly

o When you register and create an account with Us using the Application, you must provide Us with certain Personal Information, including your name, e-mail address, telephone number.

o When you use the Application, you must provide us with relevant information that may be required by Us for the application to function, for example if you use the application as a user, you must provide the information to Us according to the type of service you are looking for.

Information collected whenever you use the Application or visit Our website

o Each time you use the Application or visit our website, We may collect certain technical data in connection with your usage such as internet protocol address, previous viewed web page or subsequent web page information, duration of each visit/session, internet device identity or media access control address, Mobile Advertising ID and other device information including information about the manufacturer, model, and operating system of the device you are about to use in accessing our Application or website.

o When you use the Application or visit Our website, certain information may also be collected by using cookies automatically. Cookies are small data files that stored on your computer or mobile device. We use cookies to track user activity with the aim of improving the user interface and user experience. Most of mobile devices and internet browsers support the use of cookies; however you may adjust the settings on your mobile device or internet browser to refuse certain types of cookies or specific cookies.Your mobile device and/or your browser also allows you to delete any cookies that have been previously stored. However, it might affect the available functions on Our Application or website. o Each time you use the Application via a mobile device, We will track and collect the information based on your real time geographic location. In some cases, you will be asked or required to activate the Global Positioning System (GPS) on your mobile device to make it easier to choose a location for delivery of goods or shipping costs, and enable Us to provide you with a better experience using the Application. You can temporarily disable geo-location tracking information on your mobile device. However, this may affect the available functions on the Application.

Information collected from third parties We may also collect your Personal Information from third parties (including agents, vendors, suppliers, contractors, partners, and other parties who provide services to us, perform tasks on Our behalf, or with whom We collaborate). In such cases, We will only collect your Personal Information for or in connection with purposes involving such third parties or the purposes of Our cooperation with such third parties (depending on the situation).

Information about third parties that 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 individual). You will of course need their prior consent to do so - see "Recognition and Approval", below, for more information.

1. USE OF THE PERSONAL INFORMATION WE COLLECT

We may use the collected Personal Information for the following purposes as well as for other purposes permitted by applicable laws and regulations ("Purposes"):

o to identify and register you as a user and to administer, verify, deactivate or manage your account;

o to facilitate or enable any verification that in our opinion is necessary before we register you as a user, including the Know Your Customer process;

o to process and facilitate your orders and payment transactions; o to communicate with you and send you an information in connection with the use of the Application;

o to notify you of any updates to the Application or changes to the services provided;

o to process and respond inquiries and suggestions received from you;

o to maintain, develop, test, improve and personalize the Application to meet your needs and preferences as a user;

o to monitor and analyze user activity, behavior and demographic data including habits and usage of various services available on the Application;

o to offer or provide services from Our affiliates or partners; and o to send you direct or focused marketing communications, advertisements, vouchers, surveys and information, and information about special offers or promotions.

o to perform related business processes and functions;

o to monitor the use of the Application and manage, support and improve the efficiency of the performance, development, user experience and functions of the Application;

o to provide assistance in connection with and to resolve technical difficulties or operational issues with the Application or services; o to generate statistical information and analytical data for the purposes of testing, research, analysis, product development, commercial partnerships and collaborations;

o to prevent, detect and investigate any prohibited, illegal, unauthorized or fraudulent activity;

o to facilitate business asset transactions (which can be in the form of mergers, acquisitions, or asset sales) involving Us and/or Our affiliates; and

o to enable Us comply with all obligations under the applicable laws and regulations, (but not limited to responding to requests, investigations, or regulatory directives) and conduct audits, due diligence and investigations.

2. PROVISION OF PERSONAL INFORMATION THAT WE COLLECT

o We may disclose or share your Personal Information with affiliates and other parties for the following purposes and for other purposes permitted by applicable laws and regulations:

o if required or permitted by applicable laws and regulations (including but not limited to responding to inquiries regarding regulations, investigations or guidelines, or complying with statutory filing and reporting requirements or conditions), for the purposes specified in the laws and regulations applicable;

o if instructed, requested, required or permitted by the authorized government, for the purposes as stated in the government policies, regulations or applicable laws and regulations;

o if there is any kind of legal process between you and Us, or between you and another party, in connection with, or regarding the service, for the purposes of such legal process;

o in connection with any verification process that We or Our necessary service providers before We register you as a user;

o in the event of an emergency relating to and/or your safety (whether you are a user or a service provider) for the purpose of dealing with the emergency; o In terms of related to your health or public interest (whether you are a user or service provider), We may provide your Personal Information to the authorized government and/or other institutions that may be appointed by the authorized government or have cooperation with Us, for the purpose of contact tracing, supporting government initiatives, policies or programs, public health and other purposes as reasonably necessary;

o in connection with merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or partial of Our business by or to another company, for the purposes of such transactions (even if the transaction is subsequently discontinued);

o to third parties (including agents, vendors, suppliers, contractors, partners, and other parties who provide services to Us or you, perform tasks on Our behalf, or parties with whom We enter into commercial cooperation), for or in connection with the purpose in which such third party is involved, to carry out disclosures to the relevant third party that are technically necessary to process your transaction or the purpose of Our cooperation with the third party (depending on the circumstances), which would involve allowing the third party to introduce or offer products or services to you, authenticate you or link you with an Account or perform other activities including marketing, research, analysis and product development;

and o In the event that We share Personal Information with affiliates, We will do so with the intention that they assist Us in providing the application, to operate Our business (including, when you subscribe to our mailing list, for direct marketing purposes), or for the purpose of processing data on Our behalf. For example, a Posy affiliate in another country may process and/or store your Personal Information on behalf of Posy in your country. All of Our affiliates are committed to processing the Personal Information they receive from Us in accordance with this Privacy Policy and applicable laws and regulations.

o At the time when, Personal Information does not need to be associated with you, We will make reasonable efforts to remove the Personal Information from being associated with you as an individual prior to disclosing or sharing such information;

o We will not sell or lease your Personal Information.

o Other than as set out in this Privacy Policy, We may disclose and share your Personal Information if We notify you and We have obtained your consent for such disclosure or sharing.

3. STORAGE OF PERSONAL INFORMATION

o Your Personal Information shall only be stored as long as necessary to fulfill the purpose for which it was collected, or as long as such storage is required or permitted by applicable laws and regulations. We will stop storing Personal Information, or remove the intention of relating such Personal Information to you as an individual, as soon as it is deemed that the purpose for which the Personal Information was collected is no longer required by storing Personal Information and storage is no longer necessary for business or legal purposes.

o Please note that there still be a possibility that some of your Personal Information is stored by other parties, including government institutions in particular way. In the event that We provide your Personal Information to authorized government institutions and/or other institutions that may be appointed by the authorized government or have cooperation with Us, herewith you agree and acknowledge that the storage of your Personal Information by the relevant institutions shall follow the data retention policies from each such proprietary institutions. Conveyed Information through communications between users and service providers in which conducted other than through the use of the Application (such as through telephone calls, SMS, cellular messages or other means of communication). Information conveyed through communications between users and service providers conducted other than through the use of the Application (such as through telephone calls, SMS, cellular messages or other means of communication) may also be stored in several ways. We are explicitly not allowing such way of Personal Information storage and We shall not be responsible for your such Personal Information storage Hence You agree to indemnify, defend and hold harmless Us, Our officers, directors, employees, agents, partners, suppliers, contractors and affiliates from and against any and all claims, losses, liabilities, costs, damages and costs (including but not limited to (not limited to legal fees and expenses and full amount of compensation fees) resulting directly or indirectly from any unauthorized storage of your Personal Information.

4. ACCESS AND CORRECTION OF PERSONAL INFORMATION

o Subject to the applicable laws and regulations, you may request us to access and/or correct your Personal Information which is in our possession and control, by contacting us at the details provided below.

o We reserve the right to refuse your request to access, or to correct, some or all of your Personal Information in our possession or control if permitted or required under applicable laws. This includes situations where the Personal Information may contain references to other people or where a request for access or a request for correction is for reasons that We deem irrelevant, not serious or difficult.

5. CROSS-BORDER TRANSFER DATA

o The Personal Information we collect from you may be stored, transferred, or processed by third party service providers. We shall use all reasonable efforts to ensure that all such third party service providers give a level of protection commensurate with our commitments under this Privacy Policy;

o We shall comply with all applicable laws and regulations and use all our best efforts to ensure Our Affiliates in other countries and all third party service providers give a level of protection equivalent to our commitments in this Privacy Policy.

7. YOUR PERSONAL INFORMATION SECURITY

The confidentiality of your Personal Information is the most important thing to Us. We will use our best efforts to protect and secure your data and Personal Information from unauthorized access, collection, use or disclosure and from unlawful processing, accidental loss, destruction and damage or similar risks. However, sending information over the internet is not completely secure. Thus, We will try our best to protect your Personal Information, you acknowledge that We cannot guarantee the integrity and accuracy of any Personal Information you transmit over the Internet, or guarantee that such Personal Information will not be intercepted, accessed, disclosed, altered or destroyed by unauthorized third parties, due to factors beyond Our control. You must be responsible for maintaining the confidentiality of your Account details, including your password from anyone and must always maintain and be responsible for the security of the device you use.

8. CHANGES TO THE PRIVACY POLICY We may review and amend this Privacy Policy at our sole discretion from time to time, to ensure that this Privacy Policy is consistent with Our future developments, and/or changes in law or regulatory requirements. If We decide to change this Privacy Policy, We will notify you of such changes through a general notice published on the Application and/or website, or vice versa to your e-mail address listed in your Account. You agree that it is your responsibility for reviewing this Privacy Policy regularly in order to receive the latest information on our data processing and data protection practices, and thus by continuing to use of Our Application or website, communicating with Us, or accessing and using the services after any changes over this Privacy Policy shall be deemed as your agreement to this Privacy Policy and any amendments thereto.

9. RECOGNITION AND APPROVAL

o By agreeing to the Privacy Policy, you acknowledge that you have read and understand this Privacy Policy and agree to all its terms. In particular, you agree and give Us a consent to collect, use, share, disclose, store, transfer, or process your Personal Information in accordance with this Privacy Policy;

o Under circumstances in which you provide Us a Personal Information relating to another individual (such as Personal Information relating to your spouse, family member, friend, or other party), you represent and warrant that you have obtained the consent of that individual to, and hereby consent on behalf of such individual to, the collection, use, disclosure and processing of their Personal Information by Us;

o You may withdraw your consent to any or all collection, use or disclosure of your Personal Information at any time by providing Us the reasonable notice in writing using the contact details specified below. You can also withdraw your consent to the sending of certain communications and information from Us through the "opt-out" facility or the "unsubscribe" option available in our messages to you. Depending on the circumstances and nature of the consent you withdraw, you must understand and acknowledge that after the withdrawal of such consent, you may no longer be able to use the Application or the service. Withdrawal of your consent may result in the termination of your Account or your contractual relationship with Us, with all rights and obligations arising that must be fulfilled. Upon receiving of notification to withdraw consent for the collection, use or disclosure of your Personal Information, We will inform you the possible consequences of such withdrawal so that you can decide whether you wish to withdraw consent.

10. PROMOTIONAL MATERIALS AND MARKETING

We and Our partners may send you direct marketing, advertising and promotional communications via push-notification Apps, messages via the App, post, telephone calls, short message services (SMS), WhatsApp, social media and email ("Marketing Materials") if you have agreed to subscribe to Our mailing list, and/or agree to receive marketing and promotional materials from us. You may opt-out of receiving such marketing communications at any time by clicking on the "unsubscribe" option in the relevant message, or contacting Us via the contact details listed below. Please note that if you choose to opt out, We may still send you non-promotional messages, such as receipts or information about your account.

11. ANONYMOUS DATA

We may create, use, license or disclose the available Personal Information, provided that, (i) that all identifiable items have been removed so that the data, either single or in combination with other available data, cannot be linked to or associated with or cannot identify an individual, and (ii) similar data have been combined so that the original data will partially form of a larger data set.

12. THIRD PARTY PLATFORMS

o Apps, websites and Marketing Materials may contain links to websites operated by third parties. We do not control or accept responsibility or liability for this website and for the collection, use, maintenance, sharing or disclosure of data and information by such third parties. Please read the terms and conditions and privacy policies of these third party websites in order to find out how they collect and use your Personal Information;

o Advertisements contained on our Applications, websites and Marketing Materials serve as links to advertisers' websites and thus any information they collect based on your clicks on those links will be collected and used by relevant advertisers in accordance with the advertiser's privacy policy.

13. SEVERABILITY

If a provision of this Privacy Policy is declared invalid, illegal or unenforceable for any reason by law or other public policy, such invalidity will be limited to the invalid or unenforceable provision and the remaining provisions of this Privacy Policy will remain in full effect.

14. HOW TO CONTACT US

Should you have any questions regarding this Privacy Policy or you wish to gain access to and/or make corrections to your Personal Information, please contact sales@posy.co.id .
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