Privacy Policy

Effective as of 5 November 2021

 

This Privacy Policy (“Privacy Policy” or “Policy”) is provided by PT Solusi Sirkular Indonesia (“Koinpack”, “Company”, “we”, “us” or “our”) and is an integral part of the Terms and Conditions of use of Koinpack App.

 

We are committed to protect and respect Your Personal Data privacy and in complying with the applicable laws and regulations on data protection and privacy in Indonesia.  

 

This Privacy Policy sets out the basis on which we, our assigns, affiliates, and related companies, will collect, process, store, disclose and protect any Personal Data we collect from you or that You provide to us in connection with the use of our App, with the products and services (collectively known as “Services”) that we offer, or with any interaction with us i.e., by participating in our survey).

By using this App, you signify that you have read, understand, and agree to be bound by the Privacy Policy, regardless of whether you have registered to use any of our Services. Please read the Privacy Policy very carefully. If you do not wish to be bound by Privacy Policy, you should not access or use the App or Services.

 

Our App and Services entail that you provide us with information we can use to better understand you as our customer. Your privacy is our utmost concern and we will ensure that it will always be respected.

 

Your privacy is important to us. This Policy is intended to help you understand:

 

  • Information We Collect and Receive

  • How we Use Information

  • How We Share and Disclose Information

  • How we Store and Secure Information

  • How to Access and Control Your Information

  • Other Important Privacy Information

 

INFORMATION WE COLLECT AND RECEIVE

 

Koinpack will collect the following information that You provide to use during the registration process or when You make changes to the registered Account.

 

  • Full Name;

  • Telephone number;

  • Application’s password;

  • Business Name (optional); and

  • Business Address.  

 

Additionally,  once registered, we can obtain the following information:

  • Customer Data, such as username, phone number, and address;

  • Payment details;

  • Information on the payments performed to load your Account;

  • Information on oders, including products, date, time when the order was performed, amount charged, method of payment

  • Information on the amount of sachet and pouch that you avoid generating because of using the Services and selling the products to the Customer;

  • Information on how You interact with the App, such as date, time of entry, failures or flaws in the App;

  • Information on communication performed with Koinpack, detailing contents, date and time performed;

  • Koinpack collects information that your smartphone sends whenever you visit our App (“Log Data”). Log Data may include information such as your Internet Protocol (IP) address, time and date of our visit, the time spent on the App and other statistics. In addition, Koinpack may use third party services that collect, monitor and analyze this information.

 

In case when giving out Your information, we come across Personal Data of third parties, You will have to declare and guarantee to Koinpack that you have all the necessary authorizations from the third parties involved, in order to submit their information, according to the law applicable; and that you also become responsible for any complaint from that third party against Koinpack, for that particular issue.

 

Koinpack may request some type of bill or document, and some additional information in order to confirm that the Personal Data shown when creating the Account is that of the person itself (for example by sending you a link and/or verification code to Your phone number). Additionally, Koinpack may temporarily or permanently suspend those users whose details could not be confirmed.

 

Especially for the Customer Data, You must obtain prior verbal consent from Customers and ask them to read the Terms and Conditions and Privacy Policy of Koinpack before You input their data in the App. Please bear in mind that this is not mandatory and Customers may refuse to provide such information.

Once you input the Customer Data, Koinpack understands that You have obtain Customer’s consent and You release Koinpack from any claims from Customers for the collection of Customer Data which was not in accordance with the foregoing.

 

Koinpack may also obtain other Personal Data from public access sources and third parties that give us your Personal Data, in accordance with the law; information which we will always treat in compliance with this Privacy Policy.

HOW WE USE INFORMATION

We will collect and conserve, and in general, deal with your Personal Data for the following purposes:     

 

  • Provide Services and/or deliver Products;

  • Carry out promotion;

  • Contact you to reply to your queries or doubts or solve your complaints;

  • Send information relative to Services and Products (for example, related to future or up-coming promotions or launch of new products, events, or business information);

  • Send you surveys;

  • Apply business intelligence, perform statistical analysis and create profiles, including the subsequent anonymisation of your data once these activities have been performed;

  • Comply with legal obligations, regulate with legal, regulatory or judicial, administrative or authority orders.

  • In what is strictly necessary for the negotiation and implementation of an acquisition or merger of Koinpack by another company, which in such a scenario will become controller of your Personal Data, assuming the rights and obligations that today assist Koinpack as controller;

  • Correct operation and management of the contents of the App; and

  • Improvement of our Services and determination of the products we offer.

Koinpack will neither sell nor share your Personal Data with third parties any differently to what is shown in this Privacy Policy.

In the event Koinpack wanted to use your Personal Data for purposes other than those indicated, we will duly inform you and, if and when required – according to the applicable legislation – we will request your authorization.

HOW WE SHARE AND DISCLOSE INFORMATION

 

Koinpack will never share your Personal Data with third parties, neither in Indonesia nor abroad, except as provided in this Privacy Policy.

Herewith, You authorize us to share your Personal Data with:

  • Our suppliers who provide us with services, for the sole effect of providing us with those services, (for example, our cloud service provider – in order to store your data). These third parties will handle Your Personal Data in lieu of and on behalf of Koinpack (whom will continue to be responsible for them). We do not authorize our service suppliers to use or disclose Personal Data, except when this is necessary in order to offer specific services on our behalf or when they must comply with legal requirements or meet regulations.

  • Any company controlled by or in shared control of with Koinpack, for any purpose permitted by this Policy.

 

In addition, You authorize us to disclose or transfer Your Personal Data in the following cases:

  • Negotiation or implementing of an acquisition or merge of Koinpack by another company. In the event we sell or transfer part of or all of our businesses or assets, we would be able to transfer your Personal Data. In such a scenario, we would arbitrate reasonable means for the assignee, the new data controller, to use the Personal Data in compliance with this Privacy Policy. After the sale or transfer, you will be able to contact the entity to which your Personal Data has been transferred to in order to make any necessary query regarding the processing of your Personal Data;

  • If this is required by law, a regulation, circular, or a judicial process.

  • When we deem it necessary or appropriate to avoid physical harm or financial loss, or in connection with an investigation of alleged or actual fraudulent or illegal activities. The Personal Data shared in those cases will be the minimum necessary to comply with the request; and

  • In the event You were to file a claim for defects or regulatory breaches with regard to the products, we can share your Personal Data with the collaborating company which owns the brand, for the processing of and ultimate solution to Your claim.

Furthermore, we will be able to share statistical information that does not identify you with our business partners, and once we have anonymized your Personal Data, that is, when they do not identify you or enable you to be identified via the use of that information, and therefore they are no longer Personal Data, we can sell or transfer said anonymous data to third parties.

 

HOW WE STORE AND SECURE INFORMATION

 

Security Information

We use cloud system to host the information we collect, and we use technical measures to secure your data. While implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the internet, we cannot guarantee that data, during transmission through the internet or while store on our system or otherwise in our care, is absolutely safe from intrusion by others.

 

How long we keep information

How long we keep information we collect about You depends on the type of information. After such time, we will either delete or anonymize Your information or, if this is possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible by determination of Koinpack or based on your request.

 

HOW TO ACCESS AND CONTROL YOUR INFORMATION

 

You have certain choices available to you when it comes to your information. Below is a summary of those choices:

 

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. You may send these requests to our Data Protection Officer at indonesia@enviu.org (Bintang Ekananda). You will receive notice and/or confirmation on the status of these requests.

 

Your request and choices, however, may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. In addition, we will still process and share in the instances provided under applicable laws and regulations.

 

Our Services and related documentation give you the ability to access, update, or delete certain information about you from within the Service. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

 

OTHER IMPORTANT PRIVACY INFORMATION

 

This Privacy Policy is effective as of 5 November 2021 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this App. Your continued use of the Services/App after we post any notifications to the Privacy Policy will constitute your acknowledgement of the changes and your consent to abide and be bound by the modified Privacy Policy.