Obbidy - Privacy Notice

A. INTRODUCTION
WHO WE ARE	We are PT Transformasi Eksistensi Digital (‘We’ or ‘Obbidy’), a limited liability company that manages the Obbidy.com website and other products and services. We fully understand the importance of protecting Your Personal Data as stipulated in the laws and regulations related to Personal Data including Law No. 27 of 2022 on Personal Data Protection, amendments, and its implementing regulations applicable to Us promulgated from time to time (‘PDP Law’). Therefore, We are committed to complying with all provisions of the PDP Law including its amendments and implementing regulations in order to maintain the confidentiality and protect Your Personal Data in accordance with applicable laws.
ENFORCEABILITY OF PRIVACY NOTICES	In the context of this Privacy Notice, ‘Personal Data’ means data about an identified or identifiable natural person individually or in combination with other information either directly or indirectly through electronic or non-electronic systems referred to in the PDP Law, its related regulations, as well as Section C of this Privacy Notice, which includes but is not limited to personal data contained in an identity card that can identify a person (including your photograph), telephone number, email address, personal financial data (including bank details, credit card and transaction data), email address, and your date and place of birth. This Privacy Notice and its amendments from time to time (‘Privacy Notice’) explains how We conduct the processing of Personal Data which includes the acquisition, collection, processing, analysing, storage, improvement, updating, display, announcement, transfer, dissemination, use, erasure, and/or destruction of Your Personal Data (hereinafter referred to as ‘Personal Data Processing’) through the use of the website, applications, and/or systems (if any), participation in certain promotional programmes or activities from Us and/or third parties who cooperate or have a legal relationship with Us (‘Third Party Partners’ both online and offline), as well as through other activities, services, products, and features provided on the websites, applications, and/or systems (if any) (collectively hereinafter referred to as ‘Obbidy Services’). This Privacy Notice is effective at the time you: become a user of the Obbidy Services or Our customer, including Our employees who use the Obbidy Services and/or become Our customer; and/or become (i) Our business partners, contractors, agents and/or suppliers, and/or (ii) have a legal relationship with Us for a specific purpose, such as the implementation of corporate social responsibility.
HOW TO CONTACT US	If you have any questions about this Privacy Notice, please contact Us at: [email protected].

B. YOUR REPRESENTATIONS AND WARRANTIES
Please read and understand this Privacy Notice carefully so that you are aware of how We manage and protect your Personal Data. You hereby represent and warrant that: You have read and understood the entire contents of this Privacy Notice; The personal data you provide to us is genuine, complete and accurate; You understand all the terms of this Privacy Notice and how We process your personal data in accordance with this Privacy Notice. In some situations, you may need to provide Personal Data belonging to another person (such as a spouse, family member, your employee or another party you represent) to us. If you provide another person`s Personal Data for Us to process, you represent and warrant that you have obtained the valid consent of that person or of his/her parent/guardian (if relevant). You also understand that We rely on Your representations and warranties to process such Personal Data. We shall not be liable if the Personal Data provided by You, especially Personal Data belonging to another person, is obtained unlawfully or if Your representations and warranties are incorrect. We reserve the right to request evidence of such consent from You at any time if required

B. YOUR REPRESENTATIONS AND WARRANTIES

Please read and understand this Privacy Notice carefully so that you are aware of how We manage and protect your Personal Data.

You hereby represent and warrant that:

You have read and understood the entire contents of this Privacy Notice;
The personal data you provide to us is genuine, complete and accurate;
You understand all the terms of this Privacy Notice and how We process your personal data in accordance with this Privacy Notice.

In some situations, you may need to provide Personal Data belonging to another person (such as a spouse, family member, your employee or another party you represent) to us. If you provide another person`s Personal Data for Us to process, you represent and warrant that you have obtained the valid consent of that person or of his/her parent/guardian (if relevant). You also understand that We rely on Your representations and warranties to process such Personal Data. We shall not be liable if the Personal Data provided by You, especially Personal Data belonging to another person, is obtained unlawfully or if Your representations and warranties are incorrect. We reserve the right to request evidence of such consent from You at any time if required

C. WHAT WE DO WITH YOUR PERSONAL DATA
TYPE OF PERSONAL DATA	The type of Personal Data collected from you depends on the purposes for which the Processing of Personal Data is to be achieved. The Personal Data collected is basically as follows: Identity data: including name, photo, place and date of birth, gender, and identity card along with Personal Data therein (including the Population Parent Number (NIK) and passport number). Contact Data: including email address and telephone number. Financial Data: including data on bank accounts and / or payment instruments used in transactions for the provision of Obbidy Services and financial history. Data Device: including device data that includes the type/model of the device you are using to access Obbidy Services, internet protocol (IP) addresses and geographic location data (geolocation, as needed for the provision of Obbidy Services), and cookies (use personalizes any information included as Personal Data used to access Obbidy Services as well as as you can set your cookies through your browser settings but this option can limit the speed / quality of Obbidy Services). Other Personal Data: in accordance with applicable laws and regulations. Personal Data collected as above is provided by you directly or indirectly by Third Party Partners, including through filling out forms, submitting electronic and non-electronic documents, scanning QR codes (quick responses), uploading data through websites, applications and / or system, filling out online surveys, or through other media related to Obbidy Services. For example when you register to access / obtain and / or use Obbidy Services (including in the event that you contact us), when you attend events that we or Third Party Partners organize both on a network (net) and outside the network (luring) ( including at the time of your participation in the promotion program), following fundraising (donations), as well as through activities, services, products and/or other features or sourced from Third Party Partners for example third parties related to the implementation of the Customer Due Diligence (CDD) process and in other contexts to achieve the objectives of Processing Personal Data (including from data sources that are publicly available or provided by authorized government agencies).
WHY WE PROCESS YOUR PERSONAL DATA	The Processing of Your Personal Data is for the purposes of, among others: Providing and processing Obbidy Services to You including: Providing Obbidy Services and information regarding Obbidy Services (including related changes from time to time); Implementing the provisions of laws and regulations, including the application of the Customer Due Diligence (CDD) principle and the implementation of the Anti-Money Laundering Program, Prevention of Terrorism, and Prevention of Weapons Proliferation Financing Mass Destruction in connection with the provision of the Obbidy Services to you; Respond to and resolve requests from you in connection with the provision of the Obbidy Services; Modify, improve and/or develop the Obbidy Services, including updates and/or adjustments to applications/systems related to the Obbidy Services; and/or Meet other needs as required. Implementing and improving operational activities, and complying with applicable laws and regulations Conducting research and studies related to the provision of Obbidy Services, including generating analytical data generated through data analysis and/or usage patterns for the purposes of research, analysis, testing, product development, and collaboration with Third Party Partners; Collecting payments for the provision of Obbidy Services; Conducting activities related to accounting, auditing, taxation, and reconciliation related to the provision of Obbidy Services, as well as internal administrative processes; Carrying out obligations based on agreement to you and/or to the relevant Third Party Partners (including but not limited to Third Party Partners); Prevent, detect, investigate any suspicious transactions, criminal acts, or prohibited activities including based on applicable laws and regulations; Communicate with you through various media, including to respond to questions, comments, or complaints; Process your participation in any production activities, contests, games, promotions, polls or surveys; Conduct other internal activities necessary to provide the Obbidy Service, such as troubleshooting software, bugs, operational issues, conducting data analysis, testing, and research, and to monitor and analyze usage and activity trends; Fulfilling requests in connection with law enforcement and protecting Our and/or Your rights; and/or Fulfilling other needs as necessary. Products and Promotionswhich includes Obbidy Service offers, other products, competitions, loyalty programs, prize draws, events, or other forms of promotions that are understood to be in accordance with your needs and profile. We may convey offers for products/services owned or provided by Us and/or Third Party Partners), through various media and/or methods, both verbally and in writing, including through push notifications, social media, instant messaging applications (eg WhatsApp), SMS, telephone calls, emails, QR code scanning (quick response), brochures, or other relevant electronic and non-electronic media in accordance with applicable provisions (“Other Offers”). We may carry out Personal Data Processing if We carry out corporate actions and/or other transactions, including but not limited to mergers, separations, acquisitions, amalgamations, restructuring and/or other activities involving the transfer of intellectual property rights, as involving Personal Data Processing. We may carry out Personal Data Processing if instructed or required by an authorized government agency, for the purposes as stated or regulated under applicable laws and regulations.
HOW WE SHARE YOUR PERSONAL DATA	We may obtain your Personal Data from various sources, including but not limited to: We obtain your Personal Data directly from your interactions with our services, including but not limited to account registration, use of services, and communication with our team. Third Parties: We may also obtain your Personal Data through other parties including Third Party Partners who work with us to support the provision of services, in accordance with applicable law.
	Your explicit, valid consent to this Privacy Notice; Fulfillment of the obligation of the agreement to provide Obbidy Services to you or for other needs in accordance with the provisions of this Privacy Notice; Fulfillment of legal obligations based on laws and regulations; Implementation of duties in the context of public interest, public services, or the implementation of Our authority based on laws and regulations; and/or Implementing obligations and considering business needs on the basis of fulfilling other legitimate interests while still considering the objectives, needs, and balance of Our interests as the controller of Personal Data and Your rights as the subject of Personal Data; and/or Other Basis for Personal Data Processing in accordance with applicable laws and regulations.
TYPES OF PERSONAL DATA	Some Personal Data Processing is necessary for Us to provide services to You. Without Personal Data Processing, including by Third Parties that support Our services, We cannot provide those services. This also applies to Personal Data Processing that is mandatory to comply with applicable laws and regulations.

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WHY WE SEND YOUR PERSONAL DATA	THIRD PARTIES INVOLVED	CAN YOU RESTRICT THIS DELIVERY
Provision of Obbidy Services and Operations	Third Party Partners who support the provision of Obbidy Services and Our operations	No
Product Offerings and Promotions	Other service and/or product providers who work with us	Yes
Regulatory Compliance	Government authorities	No
Processing Your Payments	Payment service providers	No

E. STORAGE AND MANAGEMENT OF PERSONAL DATA BY US
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We will process your personal data as long as you use our services and/or have a legal relationship with us , where the Processing of Personal Data is necessary to fulfill the rights and obligations in the legal relationship.	We will retain your Personal Data after you no longer use the OBBIDY SERVICE. become our user or customer or no longer have a legal relationship with Us for a certain period of time, based on the provisions of laws and regulations, your consent, and/or Our operational interests.	We strive to maintain appropriate physical, technical and procedural safeguards to protect your Personal Data from loss, misuse, copying, destruction or modification and unauthorized or unlawful access or disclosure. , lost or damaged. Furthermore, although We have taken steps that We consider best and optimal to protect Your Personal Data, We cannot fully guarantee that the security of the Personal Data You submit will be safe completely and it is at your own risk. We will not be liable for any breach of security or any action of any Third Party or any event beyond Our reasonable control including but not limited to government action, computer hacking, unauthorized access to computer data and storage devices, computer crashes, security breaches and encryption, poor quality of your internet service or telephone service, etc.	We will erase and destroy your Personal Data in accordance with provisions regulated by applicable laws and regulations.

F. TRANSFER OF PERSONAL DATA OUTSIDE THE JURISDICTION OF THE REPUBLIC OF INDONESIA
TRANSFER OF PERSONAL DATA OUTSIDE THE JURISDICTION OF THE REPUBLIC OF INDONESIA	OUR COMMITMENT TO COMPLIANCE
If you use or access the website, application and/or related systems Obbidy Services in other countries (outside the Republic of Indonesia) where our website, applications and/or systems can be accessed (“Destination Country”) , We may transfer Your Personal Data from country of origin (“Country of Origin”) to the Destination Country so that you can access our websites, applications and/or systems outside the Republic of Indonesia. You hereby understand and consent to the transfer of your Personal Data out of your home country and/or Country of Origin as described in this Privacy Notice, the details of which we may inform you of if necessary.	We will comply with applicable laws and regulations and use our best efforts to ensure a level of protection equivalent to that applicable in the Republic of Indonesia and as regulated in this Privacy Notice, including by using standards Personal Data protection contract clauses related to the transfer of Personal Data outside the jurisdiction of the Republic of Indonesia (cross-border) if relevant and necessary. We carry out an assessment of the transfer of your Personal Data outside the jurisdiction of the Republic of Indonesia for comply with the provisions of applicable laws and regulations, including ensuring instruments and risks.

G. YOUR RIGHTS AS A PERSONAL DATA SUBJECT
HOW CAN YOU EXERCISE YOUR RIGHTS	If you would like to make a request to exercise your rights as a personal data subject, you can contact us through the channels/contacts listed in Section A of this Privacy Notice. We will verify and review each of your requests. To ensure that your request is legitimate, we may ask for supporting information or documentation. Once your request is verified, we will inform you of the consequences of exercising your rights. Once you agree to the consequences, we will process your request in accordance with the time limit specified by the applicable regulations.
YOUR RIGHTS AS A SUBJECT OF PERSONAL DATA	Right to obtain information; Right to obtain access and/or a copy of Personal Data; Right to complete, update, and/or correct errors and/or inaccuracies in Personal Data; Right to terminate the Processing of Personal Data; Right to erase Personal Data; Right to portability; Right of interoperability; Right to withdraw consent to the Processing of Personal Data; Right to suspend or limit the Processing of Personal Data proportionally; and/or Right to sue and receive compensation in the event of a violation of the Processing of Personal Data based on our errors or negligence that directly harms you.
EXCEPTIONS	Please understand that based on applicable regulations, under certain conditions, we have the right to refuse your request to exercise your rights, including requests to delete or destroy some or all of your personal data that we have. This refusal may occur if required or permitted by law, especially if the request may impact the following: National defense and security interests; Law enforcement process interests; Public interests in the context of state administration; Interests in supervising the financial services sector, interests in supervising the financial services sector, monetary, payment systems, and financial system stability carried out in the context of state administration; Interests in statistics and scientific research; The need to implement the provisions of applicable laws and regulations, for example related to the implementation of the Customer Due Diligence (CDD) process and/or preventing criminal acts criminal; The reason for the request is not relevant to the Personal Data Processing activities that We carry out or to you as the subject of Personal Data; Harm the security, physical health, or mental health of the Personal Data subject and/or another person; and/or Result in the disclosure of Personal Data belonging to another person.

H. SECURITY
The confidentiality of your Personal Data is very important to Us. We will use our best efforts to protect and secure your Personal Data from unauthorized access, collection, use or disclosure, as well as from unlawful processing, accidental loss, destruction and damage or similar risks. However, because the transmission of Personal Data over the internet is not completely secure, We cannot guarantee that your Personal Data will not be intercepted, accessed, disclosed, altered or destroyed by unauthorized Third Party Partners, due to factors beyond Our control. We will also take reasonable steps to keep your Personal Data accurate and up to date as required. You are also responsible for maintaining the confidentiality of your account details. Do not share your account details, including your password and One Time Password (OTP), with anyone. Make sure you always keep the device you use secure.

H. SECURITY

The confidentiality of your Personal Data is very important to Us. We will use our best efforts to protect and secure your Personal Data from unauthorized access, collection, use or disclosure, as well as from unlawful processing, accidental loss, destruction and damage or similar risks. However, because the transmission of Personal Data over the internet is not completely secure, We cannot guarantee that your Personal Data will not be intercepted, accessed, disclosed, altered or destroyed by unauthorized Third Party Partners, due to factors beyond Our control.

We will also take reasonable steps to keep your Personal Data accurate and up to date as required.

You are also responsible for maintaining the confidentiality of your account details. Do not share your account details, including your password and One Time Password (OTP), with anyone. Make sure you always keep the device you use secure.

I. OTHER IMPORTANT INFORMATION
LANGUAGE	This Privacy Notice may be translated into languages other than Bahasa Indonesia. If there is any discrepancy between the Indonesian language version of this Privacy Notice and any other language version, the Indonesian language version shall apply.
GOVERNING LAW	This Privacy Notice is governed by the laws of the Republic of Indonesia.
CHANGES AND UPDATES TO THE PRIVACY NOTICE	We may change, supplement, and/or replace this Privacy Notice from time to time (with notice to you) to ensure that this Privacy Notice is in line with the procedures and practices carried out by Us in carrying out the Processing of Personal Data, including to comply with the provisions of applicable laws and regulations.