PRIVACY POLICY

1. OVERVIEW

This mobile application, or social media platform page (the "Application"), is operated by PT. Kurnia Ciptamoda Gemilang (collectively, "we", "us", or "our") in accordance with applicable laws and regulations. This Privacy, Data Protection, and Cookie Policy (the "Policy") explains how we use the information we collect from you when you use the Application. This Policy also applies to information we receive from you through any social media platform under our control. PT. Kurnia Ciptamoda Gemilang is responsible for your privacy when you use our Application.

We are transparent about the information we collect about you, how such information is used, and with whom it is shared. We collect your information:

  1. to improve your user experience;
  2. in a secure environment; and
  3. only when necessary.

2. PROTECTING YOUR PRIVACY

Protecting the privacy and security of our customers and visitors to our Application is of utmost importance to us. We value and understand how important privacy is to you. The processing of your personal data is carried out in accordance with the principles and legal bases stipulated under Law No. 27 of 2022 on Personal Data Protection ("PDP Law"), including, but not limited to, obtaining your consent where required, fulfilling contractual obligations, and complying with legal requirements. If you have any questions about how we protect your privacy, please contact us at [email protected].

We respect children's privacy. We will never knowingly request or use personal information from minors. If we become aware that we have collected personal information from an Application user under the age of 18, we will delete such minor's personal information from our files. By accessing and using the Application, you represent and warrant that you are 18 years of age or older. If you are under 18 (eighteen) years old, this Application is not intended for you and you are not permitted to submit any personal information to us directly. You may ask your parent or legal guardian to carry out transactions or use the Services on your behalf and for your benefit. A parent/guardian acting as the account holder and consent provider shall be fully responsible for the accuracy and legality of the data entered.

3. HOW WE COLLECT YOUR INFORMATION

To the extent permitted by applicable law, we may collect information about you when you:

  1. Complete a service application form. We may collect information such as your name, address, email address, telephone number, and your location.
  2. Register to use our Application. We may collect information such as your name, address, email address, telephone number, and your location.
  3. Contact Customer Care by email, telephone, or live chat. We may collect information such as your name, address, email address, and telephone number.
  4. Register for newsletters and other marketing content. We may collect information such as your name, address, email address, telephone number, and your location.
  5. Participate in surveys, quizzes, or prize draws. We may collect information such as your name, address, email address, telephone number, and your location.
  6. Interact with us through social media. We may collect information such as your email address, social media address/account, and your location.
  7. Come within the range of CCTV recordings at our premises or physical stores. We may collect information such as images of you.
  8. Contact us offline. We may collect information such as your name, telephone number, and your location.
  9. Interact with our partners. We may collect information such as your name, email address, telephone number, and your location.

Providing your personal information to us is not mandatory. However, if you choose not to share such information with us, you may not be able to receive an optimal overall customer experience. In accordance with the PDP Law, you have the right to refuse or withdraw your consent to the collection, use, or storage of your personal data at any time. If you wish to exercise this right, you may submit a request to refuse data storage through the contact details provided in the Application.

4. HOW WE USE YOUR INFORMATION

We may use your information for the following purposes:

  1. To operate the Application, including:
  • information regarding your membership;
  • details of your transactions (payment and refund handling);
  • providing Customer Service support to you, whether online or offline;
  • conducting surveys, prize quizzes, or promotions; and
  • communicating with you, whether online or offline, and through any platform.
  • To manage our business needs, such as testing our IT systems, conducting research and data analysis, improving our Application, and developing new products and services.
  • To prevent fraud and other malicious activities.
  • To provide you with offers relating to our products, quizzes, prizes, surveys, and promotions.
  • To provide services tailored and personalized to you, such as analyzing and predicting your interests to customize your online experience, including showing you matters that may be of interest to you.
  • To respond to your requests, such as contacting you when you have submitted questions to our Customer Care team.
  • To create new features and products that are attractive to our customers.
  • To comply with regulatory requirements or obligations.
  • To conduct investigations or take action in connection with any violation of our Terms and Conditions of Service.
  • To carry out necessary due diligence, such as credit checks.
  • To enforce our legal rights.
  • For other actions reasonably related to the purposes specified above.

We may also anonymize and aggregate personal information to ensure that you cannot be identified and use such information for data analysis and other legitimate purposes.

5. INFORMATION RETENTION

We will retain your information for as long as you maintain your account, or as long as necessary to provide our services to you, or, in the case of any contact you may have with us, for as long as necessary to provide support-related reporting and analyze trends. In addition, we retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, with a retention period of 10 (ten) years, unless a longer period is required by applicable laws and regulations.

After the retention period expires or the purpose of processing is no longer relevant, we will delete or anonymize your personal data without undue delay, unless further retention is required for national security, law enforcement, public interest, or as otherwise provided by applicable laws and regulations.

If you close your account or when your personal information is no longer required for the purpose for which it was collected or processed, we will delete or anonymize your personal data without undue delay. We will also provide you with confirmation of the deletion once the process has been completed.

We may retain certain personal data beyond the deletion period where such retention is necessary to:

  1. protect national security;
  2. support law enforcement activities;
  3. serve the public interest in the administration of government; or
  4. comply with regulatory supervision of the financial and monetary system.

In such circumstances, the retention and processing of your personal data will be strictly limited to the purposes prescribed by applicable laws and regulations.

6. MARKETING MESSAGES

If you give us permission, we will send you marketing messages by email and/or SMS to keep you informed about what we are doing and to help you view and discover our products.

We may also retain some of your information even after you close your account or when it is no longer necessary to provide services to you. This may be for purposes that are reasonably necessary, or where we are required to do so to comply with legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, by contacting our Customer Care Team.

After you do this, we will ensure that you do not receive further promotional messages. Please note that it may take several days to update all of our systems, so you may still receive messages from us while your request is being processed. This will not prevent us from providing service communications, such as order updates.

7. VIEWING ONLINE ADVERTISING

We engage in online advertising to inform you about what we do and to help you see and discover our products.

We aim to show you certain banners featuring PT KURNIA CIPTAMODA GEMILANG brands and advertisements that are relevant to you through various digital marketing networks, advertising exchanges, and social media. We also use various advertising technologies such as pixels, cookies, and advertising tag services. For more information about the technologies we use, please refer to our Cookie Policy below.

We will tailor certain banners and advertisements to your interests depending on how you use the Application (for example, your search history and content you have previously viewed).

8. SHARING YOUR INFORMATION

We do not sell your personal information to any third party. However, as an important part of providing our services to you, we share your data with the following categories of organizations:

  1. Companies located within and outside Indonesia;
  2. Professional service providers, such as marketing agencies, web Application hosts, advertising partners, and third-party platform providers, that help us operate our business;
  3. Law enforcement and fraud prevention agencies or any person required by law; and
  4. Companies that you have authorized, such as social media Applications, if you choose to link your account with us.

We may also use data processors and other related companies in the course of conducting our business. We protect your personal information through data protection agreements with such processors and related companies. These agreements comply with applicable data protection laws and ensure that any cross-border transfer of your personal data is made only to a country or entity that provides a level of protection equal to or higher than that required under the PDP Law and GDPR. These data protection agreements comply with GDPR requirements.

We may provide collected information and analysis that has been anonymized to third parties, which does not personally identify you.

If PT. Kurnia Ciptamoda Gemilang and/or its assets are sold, acquired, or merged with a third party, resulting in your personal information being transferred to such third party, we will notify you of any changes in the company's structure or ownership. Your personal data will remain protected under a privacy policy that complies with Indonesian data protection laws and standards equal to or higher than those required by the PDP Law.

If your Personal Data needs to be transferred outside the territory of the Republic of Indonesia, we will ensure that such transfer is carried out in accordance with the Personal Data Protection Law, including by ensuring that the country where the Personal Data Controller and/or Personal Data Processor receiving the data is located provides a level of Personal Data Protection that is equal to or higher than the required level, provides adequate and binding protection, or by obtaining your consent where required by applicable law.

Your consent to this Privacy Policy does not automatically constitute consent to cross-border transfers of Personal Data. Where consent is required, we will request your consent separately, and you have the right to withdraw such consent at any time.

9. COOKIES

Our Application does not use cookies or similar technologies designed to store information on your device or track your activities through cookies.

Accordingly, your use of the Application does not involve the collection, storage, or processing of your data through cookies. Any information collected and processed through the Application is carried out in accordance with the provisions set out in this Privacy Policy.

If, in the future, any changes to the Application result in the use of cookies or similar technologies, and where required by applicable laws and regulations, we will update this Privacy Policy and obtain your consent to the use of such technologies before they are implemented.

10. DATA PROTECTION

We have implemented security safeguards designed to protect your personal information, as well as other technical, physical, and organizational measures, in accordance with the PDP Law. We are committed to maintaining the confidentiality, integrity, and availability of your data, and will take all reasonable measures to prevent unauthorized access, disclosure, alteration, or destruction of your personal information. If a failure to protect personal data occurs that affects your personal data, we will provide written notification to you and to the Personal Data Protection Authority or other competent authority no later than 3 x 24 (three times twenty-four) hours after becoming aware of such failure. Although we are dedicated to securing our systems and Application, we cannot guarantee the security of any information you transmit to us. There is no guarantee that data will not be accessed, disclosed, altered, or destroyed due to breaches of our physical, technical, or managerial safeguards.

We are responsible for ensuring the accuracy and updating of the information we hold about you in accordance with applicable procedures. You are responsible for securing and maintaining the confidentiality of your password and Account/profile registration information. We are required to take reasonable steps to ensure that the personal data we process is accurate, complete, and up to date. We are not responsible for protecting any information we share with third parties based on account connections you have authorized.

We have appointed a Personal Data Protection Officer (PPDP) as required by law, who may serve as a point of contact for you and the supervisory authority regarding the exercise of data subject rights. Our PPDP can be contacted at [email protected].

We may also delegate other employees within our group to act on behalf of the DPO or to be responsible for the day-to-day collection, processing, and use of your information.

11. YOUR RIGHTS

We respect your rights under the PDP Law and GDPR. These rights include:

  1. The right to be informed about how your personal information is used;
  2. The right to access the personal information we hold about you;
  3. The right to request correction of inaccurate personal information we hold about you (although you can do most of this through My Account);
  4. The right to request deletion of your data, or to stop its processing or collection, in certain circumstances;
  5. The right to stop direct marketing messages (which you can do through My Account) and to withdraw consent for other consent-based processing at any time;
  6. The right to request that we transfer your data elements either to you or to another service provider;
  7. The right to lodge a complaint with your data protection regulator;
  8. The right to withdraw your consent by writing to our Customer Care email; and
  9. The right to refuse or object to the automated storage or processing of personal data, including through certain types of cookies or similar technologies, where applicable.

If you wish to exercise your rights, lodge a complaint, or simply have a question, please click here to contact our Customer Service team or click here or contact our Customer Care team.

12. CHANGES TO HOW WE PROTECT YOUR PRIVACY

We may change this Policy from time to time to reflect how we process your data. If we make significant changes, we will make them clear in our web Application or other services, or through another means of contact such as email, so that you can review the changes before you continue using our Application. If you object to any changes, you may close your account.

You acknowledge that your continued use of our services after we publish or send notice of changes to this Policy means that the collection, use, and sharing of your personal information will be subject to the updated Policy.

13. HOW TO CONTACT US

If you:

  1. Have questions or feedback about this notice;
  2. Want us to stop using your information; or
  3. Want to exercise your rights as described above, or lodge a complaint,

Please do not hesitate to contact our Customer Care Team, who will be happy to answer any questions you may have. You may also contact our Customer Care Team through:

Email: [email protected]

WhatsApp: +62 8111 837 877