Privacy Policy
PT Sumber Data Indonesia (hereinafter referred to as "We" or "Our") respects and protects your privacy data is an integral part of our business and we do not see this as a burden but rather a form of our commitment to maintaining your confidentiality and trust. Our seriousness and commitment to respect and protect your personal data is supported by the following principles :
- TRANSPARENT: We are TRANSPARENT about what, why and how We collect and protect YOUR PERSONAL DATA so YOU can make informed decisions.
- RIGHT: We respect YOUR RIGHTS as an individual, so YOU are in control of YOUR PERSONAL DATA.
- USE: We USE YOUR PERSONAL DATA for specific purposes and those that We state and will keep it only for as long as necessary.
- SECURITY: We have established strict CYBER SECURITY in line with leading standards to protect YOUR PERSONAL DATA that YOU have shared with Us.
- REFERENCE: With YOUR CONSENT or in accordance with APPLICABLE LAW, We may TRANSFER YOUR PERSONAL DATA and will take appropriate steps to ensure it is adequately protected.
- TIME PERIOD: We store YOUR PERSONAL DATA for a certain PERIOD as long as it is deemed necessary. You have the right to submit a request to Us to delete YOUR PERIOD after the said PERIOD has passed.
This Privacy Notice applies to the personal data that We collect, obtain or use when You subscribe to any of Our products and services, use Our services, software tools, other services and functions We provide or visit Our websites (hereinafter collectively referred to as "Our Services") unless a separate or additional privacy policy is offered. We recommend that You read this Privacy Policy in conjunction with Our product/service Terms and Conditions as they may contain product/service specific information about how We process Your personal data. This Privacy Policy applies to :
- All of our services offered by us to you.
- Current, existing and potential customers.
- Stakeholders such as business partners, suppliers, prospective employees and parties who use our Services.
- Other parties who have an interest in us, such as guests or visitors to all branches or events.
Collection of Personal Data
We collect and use your personal information with your knowledge and consent and occurs when you :
- Using our various products and services that we offer or that you may choose to use;
- Ask customer questions, register for information or other services;
- Respond to communications from Us (such as SMS, electronic mail (email), WhatsApp, questionnaires or surveys);
- Interacting with the sites we operate, such as submitting application forms, completing survey forms, and using online services. (If your browser has internet cookies enabled, this may facilitate us in tracking your personal preferences, pages visited, etc.);
- Participate in social media pages managed by Us, such as Meta, Instagram, Twitter, LinkedIn, and other social media;
- Participate in Our promotional events, incentives or loyalty programs;
- Participate in our employee recruitment activities through our website, social media, and/or other related recruitment media;
- Providing information through Our customer call centers and sales channels; or through other affiliation or business transactions with Us, where You have consented to provide Your personal information.
Types of Personal Data
The types of personal data information that we may collect include, but are not limited to :
1. For Customers
- contact information (such as name, address, email address and telephone/mobile number);
- Identification information such as Resident Identity Card (KTP), Passport Number and Taxpayer Identification Number (NPWP), Family Card (KK);
- Banking information (such as direct debit and related bill payment banking transactions);
- Operating system type and version, hardware version, device settings, software type, battery and signal strength, screen resolution, device ID (International Mobile Equipment Identity), manufacturer and model, language, and internet browser type and version. The name and version of Our Services (such as applications) that you use are also collected by Us;
- Geographic location information, such as location derived from your IP or GPS address, Base Station, Bluetooth or Wi-Fi signals, satellites, telecommunications towers and information about how you engage with and use Our Services, for example when you choose to enable the Services to enable location on the device you use to access the Services;
- We collect information from and about a variety of technologies through which our Services are used. The types of information collected depend on the technology, usage, and personal device and settings. Examples of these technologies include computers, phones and tablets, as well as interactive wearable devices, connected technology in the home or other vehicles.
2. For Business Partners and Vendors
- Contact information (such as name, address, e-mail address and telephone/mobile number);
- Identification information (such as Kartu Tanda Penduduk (KTP), Passport Number, Nomor Pokok Wajib Pajak (NPWP), or nomor Badan Penyelenggara Jaminan Sosial (BPJS), Driving License (SIM));
- Business information (such as organization name, job title, department, office address, organizational structure, shareholders, directors);
- Any recordings taken through Our communication platforms (such as telephone recordings, Google Meet, Microsoft Teams, Zoom, etc.);
- Details contained in business registration documents, third party due diligence documents, trade references and credit checks;
- Financial details including bank account details and bank account statements;
- Geographic location information, such as location derived from your IP address or GPS, Base Station, Bluetooth or Wi-Fi signals, satellites, telecommunications towers and information about how you engage with and use our Services, for example when you choose to enable location on the device you use to access the Services.
3. For Guests or Visitors to All Branches or Events
- Contact information (such as name, address, e-mail address and telephone/mobile number);
- Identification information (such as National Identity Card (KTP), passport number, etc.);
- Business information (such as organization name, etc.);
- Reason for visiting;
- Date and time of visit;
- Security notes (special instructions and access restrictions);
- Image and/or video recordings taken or recorded by our CCTV system or other recording systems;
- We also collect the type and version of your operating system, hardware version, device settings, software type, battery and signal strength, screen resolution, device identity (International Mobile Equipment Identity), manufacturer and model, language, and type and version of your internet browser, the name and version of our services (such as applications) that you use;
- Geographic location information, such as location derived from your IP or GPS address, Base Station, Bluetooth or Wi-Fi signals, satellites, telecommunications towers and information about how you engage with and use Our Services, for example when you choose to enable location-enabled services on the device you use to access those services;
- Some of our Services allow you to use biometric information for identification or authentication or to take advantage of certain features. Biometric data may include voice, audio, video, or similar unique physical characteristics;
- We collect information from and about several types of technology through which our Services are used. The types of information collected depend on the technology, usage, and personal device and settings. Examples of these technologies include computers, phones and tablets, as well as other interactive devices, connected technology in the home or vehicle.
4. For Applicants, Candidates and Beneficiaries
- Contact information (such as name, address, e-mail address and telephone/mobile number);
- Identification information (such as Identity Card (KTP), Family Card (KK), Passport Number, Nomor Pokok Wajib Pajak (NPWP), or nomor Badan Penyelenggara Jaminan Sosial (BPJS), Driving License (SIM));
- Demographic information (such as age range, marital status, gender, etc.);
- Financial information (such as beneficiary's income, pay slip, name and bank account number, etc.);
- Educational information (such as field of study, university, country of study, academic grades and achievements, professional certifications, etc.);
- Employment information (such as employer name, address, email address, telephone number, position employed, length of employment, etc.);
- Any photos or video recordings submitted to Us (such as profile photos, contest submissions, etc.).
Additional Personal Data
You are required to provide such additional sensitive/specific personal data if you enter one of Our premises or attend one of Our events during a time of crisis such as war, terrorism, riots, natural disaster or health crisis/disease outbreak, collecting :
- Physical health condition;
- The health conditions of individuals in your household;
- Your health test results, if any;
- Are you currently or have you ever been in self-isolation when you are or have been sick;
- Body temperature
Personal Data Users
Your personal data may be collected, used or processed by Us for, among other things, the following purposes :
1. For Our Services and Products
- To provide Our products, services and offers that may be of interest to you.
- To notify you about benefits and changes to the features of our products and services.
- To provide you with Our latest offers, campaigns and promotions (where you have subscribed to such updates).
- To understand how you interact with Our Services and provide you with the best experience.
- To provide you with the latest security, versions, features, options, and controls related to your system or device.
2. To Communicate
- To send you service messages about registering for a subscription or account with Us.
- To use your information to participate in our surveys or customer meetings.
- To enable Us to send you information via electronic mail (email), telecommunications (telephone calls or text messages ) or social media about promotions, products and services offered by selected third parties that We think may be of interest to you.
3. For Business Operations
- To process payments, respond to customer service requests.
- For research and studies that may require voluntary sharing of personal information to participate
- For business operations to perform accounting, auditing, billing, reconciliation and collection activities, including monitoring and preventing crime or fraud, protecting Our legal rights, and carrying out obligations under contracts.
4. Functionality, Development & Improvement
- To provide network connectivity, measure usage levels of Our Services, diagnose server problems, and provide security features.
- To test, modify, improve or develop Our new products, services and technologies and to identify trends.
- We may also use this information for security purposes.
5. For Advertising & Marketing
- We may use your device's physical location, combined with information about what ads you view and other information We collect, to enable us to provide personalized content and to study the effectiveness of advertising and marketing campaigns.
- You may choose to allow or deny the use or sharing of your device's location by changing your device settings, but if you choose to deny such use or sharing, We may not be able to provide you with certain of Our personalized Services and content.
Legal basis
Our legal basis for collecting and using personal information will depend on the personal information concerned and the specific context
in which the information is collected.
We need personal information to fulfill a contract with you, where we have a legal obligation to do so or where it is in our legitimate
interests to carry out the processing (such as processing for administrative purposes, direct marketing, product development or enhancement,
preventing fraud or criminal activity and supporting information security) and does not override your data protection interests or
fundamental rights and freedoms.
If we ask you to provide personal information to comply with a legal requirement or to fulfill a contract with you. We will make this
clear at the time of collecting the information. We will also tell you whether the requirement for the information is mandatory and
explain any consequences to you if you do not provide the information.
Similarly, if We collect and use your personal information based on Our legitimate interests (or those of any third party), We will take
reasonable steps to provide clear notice and describe Our legitimate interests.
We are the Data controller of all personal information collected, unless an additional privacy notice states otherwise. Contact details
for Us are set out in the “Contact Us” section below.
If you have questions about or require further information regarding the legal basis for Us to collect and use your personal information
for any particular processing activity, please contact Us using the contact details provided in the “Contact Us” section below.
Information Regarding Children
If you are under 18 years of age, you are obliged to obtain the consent of your parents or legal guardian before using our network, products and/or services.
Information Regarding Disabilities
If you are a person with a disability who requires a guardian, then you are obliged to obtain the consent of your legal guardian before using our network, products and/or services.
Storage (Retention)
Personal data that has been collected and will be retained for the period necessary to fulfill the purposes mentioned above. We may retain
your personal data to provide the services you have requested, or for other essential purposes, such as complying with Our legal obligations,
resolving disputes, and enforcing Our policies. The retention period for personal data is based on applicable legal requirements. However,
in the absence of relevant laws, personal data will be retained for the period necessary for business purposes.
This personal data can be stored in the form of :
- Printed copy, or;
- Electronic format
We may store your data in data centers or warehouses managed either by Us or by service providers on Our behalf. All of Our facilities,
systems and products are equipped with the necessary security controls to ensure the protection of personal data.
Retention periods can vary widely based on the type of information and how it is used and Our retention periods are based on criteria that
include legally required retention periods, pending or potential litigation, Our intellectual property or proprietary rights, agreement/
contractual requirements, operational directives or needs, and historical archiving. When personal information is removed from Our systems,
it is deleted or destroyed using appropriate security protocols so that it cannot be reconstructed or read.
Third Party Sites & Services
This Privacy Notice does not address, and We are not responsible for, the policies and practices of third parties or other organizations not operating on Our behalf, including policies and practices relating to privacy and security, data collection, processing, use, storage, and disclosure. This includes :
- Any third party operating any site or service to which Our Services link - the inclusion of a link on Our Services does not imply endorsement by Us or any of Our affiliates of the linked site or service; or
- Application developers, application providers, social media platform providers, operating system providers, wireless service providers or device manufacturers (such as Facebook, Apple, Google, Microsoft, Instagram, LinkedIn and others) - including personal information you disclose to other organizations through or in connection with Our Services or Our company's Social Media Pages
Automatic Decision Return
In some cases, Our use of your personal information may result in automated decision-making (including profiling) that legally affects you or significantly affects you. Automated decisions are decisions about you made automatically based on the results of computer decisions (using software algorithms), without any human review, where such decisions have legal or other significant effects. We use automated analytics to make predictions such as what types of products or services you may be interested in, or automated decision-making to prevent theft, fraud or other crimes. The artificial intelligence solutions provided by Us may lead to automated data processing in various areas. Where Our automated decision-making has legal effects or significantly affects you, We will implement measures to protect your rights, freedoms and interests, by conducting a privacy impact assessment to identify appropriate measures to protect those rights, or obtaining your explicit consent as required by applicable law.
Security
We strive to process your information in a secure environment by preventing unauthorized or unlawful processing of personal data or accidental loss or destruction or damage to such information. We have implemented a variety of physical, technical and administrative security measures to protect your personal data and our networks from unauthorized access. These measures include :
- Data encryption in transit or at rest
- Strict adherence to privacy and security practices
- Periodic audits and data reviews to improve our practices
- Restricting access to such data to personnel who have a need to know such data
We require our suppliers and vendors to implement similar safeguards when they access or use personal information we share with them. Users of our Services must also do their part to protect the data, systems, networks and services they use. No technology, data transmission or system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you think your password to any of our accounts has been compromised), please notify us immediately by reporting to our customer care at 08119556686.
Sharing Information
We work both internally and through our affiliates to provide some of our Services. We also work with authorized suppliers and business
partners. When we share your personal information with these companies, we take appropriate steps to limit the use of your information to
lawful and legitimate uses consistent with this Privacy Notice, as well as appropriate confidentiality and security measures. For example,
we rely on affiliates and partners, such as our freelancers, to complete purchases or provide our Services, as you request assistance with.
We also share information with third parties for advertising and marketing; when required by law or to comply with legal process; to
protect our customers; to protect lives; to maintain the security of our Services; and to protect our legal rights :
- With Our Affiliates or Related Companies (Sister Companies, Subsidiaries, Partners) To align our business strategy objectives, we also share personal information with Affiliates and Sister Companies.
-
With Suppliers/Vendors
Our authorized vendors and suppliers may need personal information to provide the services we have hired, such as service delivery, product delivery, website hosting, data analysis, IT services, auditing, payment processing or customer service. We use a variety of software and tools on our Site and we process personal information using these tools as part of our regular business activities. Our contracts with suppliers and vendors include provisions to protect your information and limit its use. We also share non-personally identifiable information, such as anonymized or aggregated information, with suppliers for purposes such as analytics, identifying trends in our product areas and to help research and describe our new Services. -
With Partners
We have relationships with third parties who are not suppliers or vendors but who work with us to offer certain opportunities such as sweepstakes, contests and similar promotions, to produce joint products or research studies, or to facilitate services such as message boards, blogs or other shared media. In these cases, additional terms or privacy notices may be provided. For third parties or uses not described in this Privacy Notice, We provide your information only on a valid legal basis. -
For Advertising and Marketing
We share your information with our third-party corporate partners to prepare and deliver advertising and marketing content, to provide content services and enable them to provide you with more personalized advertising and to study the effectiveness of our campaigns.
We use third party companies to communicate about goods and services that may be of interest to you, based on your preferences. You may receive this content in a variety of ways such as by email, telephone or when you access and use Our Services and other websites. The content may be based on information obtained, for example, through previous purchases or transactions, through the physical location of your device, through information about advertisements and content you have viewed, or through cookies and similar technologies relating to your access to and use of Our Services and other websites. You may choose to allow or deny the use and/or sharing of your device location by changing your device settings, however if you choose to deny the use or sharing, then Our partners will not be able to provide you with any of Our personalized content and Services as applicable. -
Research & Service Enhancement
We may disclose personal information to collaboration partners to conduct research to improve Our technology, or the use of Our technology, in various fields of study and to identify new uses or design new products. -
Regulatory & Law Enforcement Agencies
If We are required or required by applicable laws and regulatory requirements, court orders, administrative bodies or regulatory commissions or applicable laws or stock exchanges, We may disclose Your personal data in compliance with applicable laws, regulations or detection or investigation of crime or fraud.
We make reasonable efforts in accordance with industry best practices to ensure that related parties maintain the confidentiality of your personal data and are prohibited from using your personal data for unauthorized purposes.
Mergers and Acquisitions
We may disclose your personal information as part of a planned or actual corporate transaction such as a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or a portion of Our business, assets or stock (including in connection with bankruptcy or similar proceedings).
Communication Preferences and Choices
We take reasonable steps to keep your personal data accurate, complete and up to date. You may still opt out of receiving promotional
emails or other communications from Us by contacting Us at the contact details set out below. This choice does not apply to the receipt
of mandatory product or service communications that are considered part of a particular product or Service of Ours, which you may receive
periodically, unless you cancel that product or service.
In addition, We do not require you to provide personal information to Us. The decision to provide personal information is voluntary.
However, if you do not wish to provide the requested personal information, you may not be able to continue with the activities or receive
the benefits for which the personal information is requested.
Cross Border Data Transfer
With your consent, We may transfer your personal data across geographical borders to other entities, provided they ensure the same level of protection that We do. Transfers of personal data are carried out under Our standard contracts with appropriate data protection clauses or data transfer agreements with similar rights and obligations for the recipient of the information to protect the security and confidentiality of your personal data. We do not sell, trade, transfer, or share your personal information, except in the following cases :
- With our group companies, where necessary and within applicable legal limits.
- As required by law, such as in connection with a subpoena, government investigation, litigation, dispute resolution, or similar legal process.
- With other carriers and operators when making international call forwarding.
- If We believe in good faith that disclosure is necessary to protect Our rights, protect Your security, investigate fraud, or respond to a law enforcement request.
- With Our service providers, field technicians, contractors who work on Our behalf and who do not have independent rights to use the information to which they have access or to which We disclose to them.
- With our business partners for our marketing activities, in such cases no personally identifiable information is provided, as such information is generally aggregated.
- With third parties for research and development purposes.
- With our sister companies, subsidiaries and affiliates.
In all cases, the third party must agree to strict obligations to keep all personal information confidential and to use it only for the purposes for which it was obtained.
Withdrawal of Services
Withdrawals may be made in certain of Our services and are subject to Our consent. By withdrawing your consent for Our services, it will result in the loss of all or part of the services you receive, this means that you cannot receive or enjoy or optimize the services We provide to you.
Consequences arising from failure to provide Personal Data
You may access our website without providing your personal data. However, if any activity/service on our website/web link requires us to collect certain personal data about you, failure to provide such information may :
- Causing us to be unable to respond to your request for our products/services.
- Restrict or prevent access to certain features on our websites/web links.
- Causing us to be unable to provide you with the latest information regarding our promotions or service/product launches.
- Resulting in your inability to accept invitations to promotional activities that we organize.
Access or Correction of Customer Information
If you wish to correct or update your personal information, or to request access to your personal data held by Us, you may contact Us to
make a request in writing by using the method set out in the “Contact Us” section below. If you request a change to your personal
information, please note that We may still need to retain that information for recordkeeping purposes, and/or to complete any transactions
you began prior to requesting the change (for example, when you make a purchase or enter a promotion, you may not be able to change the
personal information provided until after the completion of that purchase or promotion). Some of your information may also remain in Our
systems and other records as necessary to comply with applicable law.
Upon your request and if the law requires us to do so, we will inform you what personal information we hold about you. You may also have a
legal right to obtain a copy of your personal information. You may make such a request by making a written request in the manner described
in the “Contact Us” section below. We may charge a processing fee for this service where permitted by law and we will require proof of your
identity before fulfilling your request.
You agree that :
- You have read and understood this Privacy Notice and consent to the use of your personal data as set out in this Privacy Notice.
- Your personal data may be transferred and processed worldwide, including to countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner set out in this Privacy Notice.
- All your statements are true and correct to the best of your knowledge, and you have not intentionally omitted any relevant information that is detrimental.
Contact us
If you have any questions or concerns about this Notice, privacy and information handling practices and exercise any of your rights set forth in this Notice. You may contact Us on Our customer care hotline at 08119556686.
Dispute Resolution
In case of any alleged/actual breach of your privacy, in relation to your information that We process or store, you may lodge a complaint with the relevant regulatory authority or any other court/tribunal with competent jurisdiction.
Updates to the Privacy Notice
We reserve the right to update this Privacy Notice, if necessary. This Privacy Notice supersedes any previous versions. We strongly recommend that you check this Privacy Notice from time to time to be informed of any changes to the Privacy Notice.
Version information: Privacy Policy updated on January 26, 2024