Privacy Policy

Personal Information you disclose to us

In short: When you create an Account and/or integrate with your Third-Party Account on the Platform, we collect your Personal Information you provide to us such as name, address, contact information, passwords, and security data, payment information, and social media login data. In addition,

the Personal Information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The Personal Information we collect can include the following:

General Personal Information. We collect ID; first name, maiden name, last name, and nickname; phone numbers; email addresses; business email; business phone number; social media; and other similar data.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access on the Platform.

Payment Data. We 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 payment data is stored and processed by our third-party payment service provider, Xendit. You may find their privacy policy link(s) here: https://www.xendit.co/en/privacy-policy/. You acknowledge and agree that you may be subject to additional terms according to the privacy policy applicable at the relevant payment service provider, and we advise you to review and check such policy.

Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called "6. How Do We Handle Your Social Logins?" below.

We collect your Personal Information based on your consent that you voluntarily provide to us when registering yourself in our Platform, expressing an interest in obtaining information about us or our products and Services, when participating in activities on the Services or otherwise contacting us. Such consent is given by filling a tick mark on the Platform and/or by any other relevant method.

All Personal Information that you provide to us must be true, complete, accurate, and does not constitute a third-party’s Personal Information, and you must notify us of any changes to such Personal Information.

Information automatically collected

In short: Some information such as internet protocol address (“IP Address”) and/or browser and device characteristics is collected automatically when you utilize and access our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include:

Online identifiers. We collect devices and usage information, such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. We also collect information through cookies and similar technologies.

This information automatically collected is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

In short: We process your Personal Information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We use your Personal Information via our Services for a variety of business purposes as described below. We process your Personal Information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

In general, we use the Personal Information we collect or receive to:

• allow you to share Content and interact with other Users on our Platform;
• allow you to participate in campaigns and/or quests organized through our Platform;
• customize the Content you receive and provide specific Content that will interest you;
• provide ads that are tailored to your preference;
• help us detect and fight abuse, malicious acts, fraud, spam, and illegal activity on the Platform;
• improve and optimize our Services;
• analyze Platform usage, identify trends, conduct data analysis, and determine the effectiveness of our marketing and promotions and other service offerings;
• mprove Users’ experience and increase the efficiency and effectiveness of the Platform’s Services and functionality offerings;
• maintain security;
• send you newsletter and mail with regard to campaigns and/or quests and/or offers through your e-mail and/or Account inbox;
• communicate with you and inform you of any changes made towards our Services; and
• comply with prevailing laws and regulations.

We may use and store this collected Personal Information in aggregated and anonymized form so that it is not associated with individual end-users and does not include personal information. We will not use your Personal Information without your consent.

In certain circumstances, we may also use your Personal Information other than those mentioned above based on your consent. If we do this, we will tell you which purposes and categories of your information that will be processed when we ask for your consent.

In short: We only share your Personal Information with your consent, to comply with the prevailing laws, to provide you with the Services, to protect your rights, or to fulfil business obligations.

We may share your Personal Information based on the following legal basis:

Consent: We may share your data if you have given us specific consent to share your Personal Information for a specific purpose.

Legitimate interests: We may share your Personal Information 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 share your Personal Information to fulfil the terms of our contract.

Legal obligations: We may disclose your Personal 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 Personal Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our Terms and/or Privacy Policy, 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 or share your Personal Information in the following situations:

Vendors, Consultants and Other Third-Party Service Providers. We may share your Personal Information with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such Personal Information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect Personal Information about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Privacy Policy, we do not share, sell, rent or trade any of your Personal Information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your Personal Information unless we have instructed them to do it. They will not share your Personal Information with any organization apart from us. They will hold it securely and retain it for the period we instruct.

Business Transfers. To the fullest extent permitted by law, we may share or transfer your Personal 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.

The Government. We reserve the right, and you hereby authorize us, to share or disclose (including, without limitation, to law enforcement agencies, public authorities, governmental departments, or other similar organizations) your Personal Information that we collect where the disclosure of such information is necessary to identify, contact, or bring legal action against you, if:

a.you are or may be violating the Terms and/or this Privacy Policy;

b.you are violating any applicable laws, rules, or regulations;

c.necessary or required by any applicable law, rules, or regulation including a subpoena or similar legal process;

d.necessary or required for purposes of public importance to protect our rights, protect your safety, or the safety of others, investigate security, technical issues or fraud, or respond to a government request; and/or

e.requested by governmental authorities in the event of any investigation, act of terrorism, or instance of regional or national emergency.

If you provide any Personal Information that is untrue, inaccurate, not current, or incomplete, we may suspend or terminate your Account. We may remove or change an username you select if we determine that such username is inappropriate.

In short: We only share your Personal Information with the following third parties.

We only share and disclose your Personal Information with the following third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have shared and disclosed your Personal Information based on your consent and you wish to revoke your consent, please contact us through the reporting tools as mentioned in the section called “16. How Can You Contact Us About This Policy?”. For further information as to how and for what purpose we share your Personal Information, please see the relevant third-party below and also the relevant third-party’s privacy policy (if any) for your comprehensive understanding with regard to the use of our Platform.

Advertising, Direct Marketing, and Lead Generation: Google AdSense.

Allow Users to Connect to their Third-Party Accounts: Google account, Facebook account, Instagram account, Pinterest Account.

Payment Service Provider: Xendit.

Web and Mobile Analytics: Google Analytics, Ahrefs.

Platform and Services Improvement and Optimization: members, subsidiaries, or other affiliates of our group of companies.

Law Enforcement: law enforcement agencies, public authorities, or other organizations, where we are legally required to do so.

In certain circumstances, we may also share your Personal Information with other third parties besides those mentioned above based on your consent and subject to prevailing data protection law. If we do this, we will tell you which categories of Personal Information and which third-party such Personal Information will be shared with when we ask for your consent.

As further elaborated in Article 5.8 of the Terms, certain Personal Information that you upload to the Platform (such as certain Account profile information), certain User Content (such as video and sound recording that you upload to the Platform), and certain Platform usage information (such as other User Content you “like”), will automatically, or upon your selection, be made publicly available to other Users on the Platform. You acknowledge and agree that certain Account information (such as Account profile name, picture, and/or User Content) that you provide in connection with: (i) the registration of your Account; and (ii) your general use of the Platform, such as uploading User Content, will be made publicly available to all Users of the Platform. We strongly advise you not to post any Personal Information that you do not want to make publicly available on the Platform.

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

We may use cookies and similar tracking technologies (like web beacons and pixels) to collect and store information during your use of the Services. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy. By using our Services, you consent to our use of cookies and similar tracking technologies. If you choose not to accept such cookies and similar tracking technologies, then you should stop using the Services, or check your third-party browsing and cookies or tracking settings.

Further, in the event of you have already accepted our cookies and such similar tracking technologies and you wish to delete them, you may be able to delete such cookies and similar tracking technologies through your browser or device settings. However, certain cookies and similar tracking technologies are required to enable the core functionality of our Services. Therefore, please note that deleting such cookies and similar tracking technologies may affect the functionality of our Services available on the Platform to you.

In short: If you choose to register or log in to our Services using Third-Party Account, we may have access to certain Personal Information about you.

Our Services offer you the ability to register and log in using your Third Party Account (social media account like your Facebook or Twitter). Where you choose to do this, we will receive certain Personal Information about you from your Third-Party Account. Such information that we receive may vary depending on the Third-Party Account concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.

We will use the Personal Information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on the Services. Please note that you hereby understand and agree that we do not control, and are not responsible for, other uses of your Personal Information by your Third Party Account provider. We recommend that you review their privacy policy to understand how they collect, use and share your Personal Information, and how you can set your privacy preferences on their sites and apps.

The Personal Information we collect from you may be stored on servers located in [*], outside the country in which you reside. We maintain main servers in several places in the world to bring our Services to you globally and continuously. In such event, Cuit.App shall ensure that the Personal Information remains protected pursuant to Cuit.App’s commitment to this Privacy Policy and comply with legal requirement set by prevailing law.

In short: We keep your Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise 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, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us to keep your Personal Information for longer than 90 calendar days past the termination of the Users’ Account.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, to the extent permitted by law, 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.

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 information we process. We strive to ensure compliance with applicable data protection legal requirements based on the relevant Indonesian laws and regulations to ensure protection and safeguard your Personal Information. We have physical, electronic, and procedural safeguards that comply with applicable laws in Indonesian jurisdiction to protect Personal Information. By accepting the terms of this Privacy Policy, you agree that the standards and practices we apply are reasonable and adequate to protect your Personal Information.

While we strive to keep current our security technology and will review, refine, and upgrade our security technology as we deem appropriate based on new tools that may become available in the future, you hereby acknowledge and agree that we cannot guarantee that the internet itself is 100% secure. Transmission of Personal Information to and from our Services is at your own risk. You should only access the Services within a secure environment.

In short: Our Services is not intended for children under 18 years of age and we do not knowingly collect, solicit data from or market to children under 18 years of age.

By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such minor and consent to such minor dependent’s use of the Services. If we learn that Personal Information from Users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us through the reporting tools as mentioned in the section called “16. How Can You Contact Us About This Policy?”.

In Short: You have rights under data protection laws relating to your Personal Information. You have rights that allow you greater access to and control, among others, to correct, update, review or request deletion of your Account that contains your Personal Information at any time.

Under data protection regulations, you have certain rights which include the right (i) to request access and obtain a copy of your Personal Information, (ii) to request rectification or erasure; (iii) to restrict the processing of your Personal Information; and (iv) if applicable, to data portability. In certain circumstances, as far as we process your Personal Information on the basis of our business purposes, you may also have the right to object to the processing of your Personal Information at any time. To make such a request, please use the contact details provided below herein by stating the grounds of your objection in order for us to examine the processing of your Personal Information and decide whether to adjust the processing accordingly. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://www.kominfo.go.id/. However, before you file a complaint with such data protection authority, we would appreciate the opportunity to address your concerns first by sending us an email through reporting tools as mentioned in the section called “16. How Can You Contact Us About This Policy?”.

Account Information

If you would at any time like to review or change your Personal Information in your Account or terminate your Account, you can: contact us using the contact information provided in this Privacy Policy.

Upon your request to terminate your Account, we will deactivate or delete your Account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of and/or comply with legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

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 will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of Personal Information. You will be notified about data breaches when PT Komunitas Karya Transformasi believes you are likely to be at risk or seriously harmed. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being.

In the event of PT Komunitas Karya Transformasi becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of Personal Information, PT Komunitas Karya Transformasi will promptly notify you in writing with regard to such security breach. Such notification will be accompanied by reasons or causes of data breach and will be sent to you electronically, through the respective Users’ e-mail, no later than 14 calendar days since the breach is known. Moreover, we will also investigate the matter and notify the applicable supervisory authority, which in this case is the Ministry of Communication and Informatics of the Republic of Indonesia, not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

Our Services may contain links to third-party websites. If you click on any of these links, please note that each will have its own privacy policy. We do not control these websites and are not responsible for those policies. When you leave our Services by clicking such links, we encourage you to read the privacy policies of each website you visit.

In short: Yes, we will update this policy as necessary to stay compliant with relevant laws and to enhance our Personal Information protection system in the use of our Platform.

We may update this Privacy Policy from time to time. The updated version will be indicated by a “Last Updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes on our Platform or by directly sending you a notification to your Account. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. If you do not agree to the updated policy, you must stop accessing or using the Services. Otherwise, you will be deemed to agree and further be subject to such updated policy.

If you have any complaints or questions about how we process your Personal Information based on this Privacy Policy, you may file such complaints or questions via the following reporting tools:

Basically, the procedure of the above reporting tools is similar to the procedures stated in Article 7 of the Terms.

This Privacy Policy is made in Indonesian language and English language. In the event of any inconsistency or different interpretation between the Indonesian language version and the English language version, you agree that the Indonesian language version will prevail to the extent of such inconsistency or conflict, and the relevant English language version is deemed to be automatically amended to be consistent with the relevant part of the Indonesian language version.