PRIVACY POLICY
INTRODUCTION
This Privacy Policy or Privacy Notice (“Privacy Notice”) is effective since May 17, 2024.
This Privacy Notice explains how PT United Tractors Tbk (hereinafter referred to as “the Company” or “We” or “Us” or “Our”) obtains, collects, stores, manages, uses, processes, analyses, updates, corrects, displays, publishes, transfers, discloses, and protects your personal data (“Processing Personal Data” or “Personal Data Processing”)
including but not limited to, name, occupation, company name, email address, telephone number, and relevant information as described in the Summary and Details sections of this Privacy Notice (“Personal Data”). Your Personal Data is collected when you are accessing Our website, along with data related to transactions and/or activities you carry out through Our Services (“Transaction Data”).
This Privacy Notice applies to all users of the Company’s websites, applications, and/or services (including https://ptunitedtractors.com and its subsidiary sites) provided by us (“Our Services”), unless otherwise governed by a separate privacy notice and/or privacy policy.
Please read this Privacy Notice carefully to ensure that you fully understand how We protect and manage your Personal Data. We aim to make this Privacy Notice as clear and accessible as possible; therefore, a summary of the key points is provided in the section below.
Acknowledgment and Consent
By agreeing this Privacy Notice, you acknowledge that you have read, understood, and accepted this Privacy Notice and all of its terms. In particular, you consent to and authorize Us to collect, use, process, and otherwise handle your Personal Data to Us in Processing Personal Data in accordance with the provisions set forth in this Privacy Notice.
If you provide Us with your Personal Data relating to other individuals (such as Personal Data relating to your spouse, family members, friends, or relevant parties as required in relation to Our Services), then you represent and warrant that you have obtained the said individual’s consent, and that you are authorized to provide such consent on their behalf for Processing Personal Data of their Personal Data by Us. We may, at any time, request evidence of such consent from you. Upon the foregoing representations and warranties, you agree to indemnify and hold Us harmless from any and all legal responsibilities.
You may withdraw your consent for any or all processing of your Personal Data at any time by: (1) providing Us with reasonable written notice using the contact details provided below, (2) selecting the “opt-out” option, (3) using the “unsubscribe” feature available in the communications We send to you, or (4) selecting the applicable option provided in the communication channels through which We contact you.
You must understand and acknowledge that after withdrawing your consent, you may no longer be able to use Our Services. Such withdrawal may result in the suspension or termination of our Services, deletion of your account, or cessation of your contractual relationship with us. All rights and obligations accrued prior to the withdrawal shall remain fully enforceable. Upon receiving your notice of withdrawal, We will inform you of the potential implications of your decision so that you may confirm whether you wish to proceed with the withdrawal of consent.
SUMMARY
What types of Personal Data do we collect?
We collect your Personal Data when you use our Services, including identification data, contact details, log data, and/or location data. We also collect device and technical information, as well as relevant data required in order to be able to use Our Services that you may provide or submit while using our Services. If you choose not to provide such data, we may be unable to deliver our Services to you effectively.
How long do we retain your personal data?
We process your Personal Data for as long as you use Our Services and have provided the necessary consent for the purposes for which it was obtained and collected, or as required under the applicable laws and regulations on Personal Data protection in Indonesia (“Applicable Laws and Regulations”).
How can you exercise your rights over your Personal Data?
You may have certain rights concerning your Personal Data under the Applicable Laws and Regulations. If you wish to exercise any of these rights, you may submit a request to us, including a request for data deletion, by contacting Us through the contact information provided in the Contact Us section.
Contact Us
If you have any questions, comments, complaints, or claims regarding this Privacy Notice, or if you wish to make any changes and/or updates to the Personal Data you have provided to Us, please contact our Corporate Communications team via email at corcomm@unitedtractors.com.
How Will We Notify You of Changes?
We may update this Privacy Notice from time to time, and We may inform you of any revised versions through our Services or via the email address you have registered with Us (where applicable). We encourage you to review this Privacy Notice periodically to stay informed about any updates or modifications.
Additional details and explanations regarding the summary above can be found in the Detailed Information section below.
DETAILS
PERSONAL DATA WE COLLECT
Personal Data refers to any information that can be used to identify, contact, or locate an individual, or a device associated with such information. It includes, but is not limited to, your name, address, date of birth, telephone number, email address, government-issued identification (such as an Indonesian identity card or other official documents issued by a competent authority), financial information, and/or relevant data that may identify an individual whether on its own or when combined with other information, as defined under the Applicable Laws and Regulations.
The types of Personal Data that We collect depend on the services you use or the transactions you carry out, either by you directly, by employees, or by other data subjects who input their Personal Data through Our Services.
The Company may process Personal Data through various activities, including collection, use, storage, data analysis, transfer, application development, as well as deletion and destruction of such data, provided that these activities comply with the Applicable Laws and Regulations and adhere to the fundamental principles of personal data processing as required by law. When you use Our Services, you are deemed to have provided consent to the processing of your Personal Data by (i) checking the consent pop-up message related to Personal Data usage displayed on the Company’s website, (ii) selecting how your Personal Data may be used, including whether you consent to receiving promotional advertisements and/or (iii) providing consent when entering your Personal Data during account registration or while using specific Our Services. The Personal Data processed by the Company is further categorized as follows:
Your Personal Data
Data Identifying includes, among others, your name, residential address, any information contained in your Identity Card (Kartu Tanda Penduduk), password, telephone number, email address, job title, tax identification information, and/or relevant information that may reveal your personal identity.
Financial data including (i) your bank account number, (ii) your credit card number, issuing bank, identification number, card verification code, card expiration date, credit scoring, and financial history when payments are made using a credit card, (iii) in cases where payments are made using financing facilities owned by you or a third party, additional data such as a copy of the financing agreement between you and such third party may be required, as well as relevant financial data necessary to verify payment.
Payment data includes proof of payment made by you through Our Services, as well as information regarding the selected payment method, billing details, invoice information, and/or other relevant data necessary to verify and confirm the payment.
Technical data includes (i) the IP address used by you when accessing our Services, (ii) Our Service usage history, (iii) products frequently accessed, (iv) duration of access for each session; (v) device-related data used to access Our Services, (vi) cookies that may be used to identify your activity within Our Services; and related data that may assist Us in providing you with relevant product information and/or personalized content tailored to your needs.
This includes your nearest delivery location for our products and/or services, and/or geolocation information captured by Our Services.
Personal Data of Company’s Employees (if you are an employee of the Company)
Personal identification data includes your name, residential address, details contained in your Identification Card (Kartu Tanda Penduduk), password, telephone number, email address, employee identification number, position or job title, tax identification information, and/or relevant information that may identify you personally.
Financial data includes, among others, your bank account number and/or relevant financial data as required by the Company in connection with your employment relationship.
Technical data includes (i) the IP address used when accessing Our Services, particularly those available to Company employees, (ii) usage history of Our Services, (iii) duration of each access session, (iv) your attendance as an employee, (v) information related to the device used to access Our Services, and/or relevant technical data related to your usage of Our Services as a Company’s employee.
Information related to your location as an employee, either as provided by you when submitting your location details or captured automatically through geolocation features that must be enabled when accessing our employee-specific Our Services.
Special information such as medical records, health information, data regarding your children, spouse information, salary details, and/or relevant data required by the Company in connection with your employment relationship as a Company’s employee.
The Company may combine the obtained Personal Data for statistical, demographic, or service development purposes (hereinafter referred to as “Combined Data”). The Combined Data, in principle, will not disclose any Personal Data. The Company will continue to ensure that the Combined Data cannot be used to identify, associate with, or link to any individual.
Accuracy and Completeness of Data
Essentially, you have the right to request corrections if any of your Personal Data is found to be inaccurate. At the same time, the Company must ensure that the Personal Data you provide is accurate and complete. Therefore, you are required to provide your Personal Data to us truthfully and in full.
In the event that you fail and/or neglect to provide complete and accurate Personal Data, then (i) you may not be able to fully utilize Our Services, (ii) you may be unable to access and/or use Our Services, or (iii) the Company shall not be held liable for any negligence and/or failure on your part to provide complete and accurate Personal Data. For the avoidance of doubt, if you fail to provide the required identification information when such identification is necessary for the execution of an agreed contract, the Company may be unable to provide the related services.
Sources of Personal Data Collection
The Company obtains Personal Data through (i) direct submission from you, (ii) data collected when you access or use Our Services, and (iii) information or data concerning third-parties provided by you.
USE OF PERSONAL DATA
How We Use Your Personal Data
By agreeing to this Privacy Notice, you expressly grant Us permission to use the collected Personal Data for the following purposes, as well as for relevant purposes permitted under the applicable laws and regulations including but not limited to (collectively referred to as the “Purposes”):
to respond to your inquiries, comments, or complaints;
to communicate with you through various channels, such as notifications within our Services, email, telephone, short message service (SMS), in-app messaging, push notifications, or social media;
for marketing and promotional activities related to our products and/or services and those of Our affiliated companies, including announcements, promotional materials, greetings, invitations, and special privileges from our affiliates, partners, sponsors, or advertisers;
to process your participation in events, contests, games, promotions, polls, or surveys;
to understand and analyze product usage and sales patterns to identify your needs and/or preferences;
to develop, improve, and deliver products and/or services that meet your needs; to fulfill legal or contractual relationships between you and the Company;
other relevant matters directly related to the provision of Our Services, provided that they do not conflict with applicable laws and regulations; and/or
for internal administrative processes and/or compliance with applicable Indonesian laws, including but not limited to audits and taxation purposes.
We take reasonable measures to protect your Personal Data and/or Transactional Data. We are committed to continually enhancing Our Service security standards. However, We cannot be held responsible for any loss or damage to your Personal Data and/or Transactional Data that occurs beyond our control. Therefore, we strongly recommend that you regularly update your account information and software and refrain from disclosing your account password to any third-party.
How We Disclose Your Personal Data
By agreeing to this Privacy Notice, you expressly consent that, for business, operational, or relevant legitimate purposes, we may collaborate with third-parties in connection with the use and processing of your Personal Data and/or Transactional Data. Such third-parties may include, but are not limited to:
research and marketing companies, in relation to the promotion of our products and/or services;information technology service providers, including those offering infrastructure services, cloud computing, software solutions, big data analytics, and machine learning — encompassing services such as data cleansing, data insight, and credit scoring;
payment processing service providers, including operators of payment gateways, fund transfer services, e-wallets, electronic money, and relevant payment systems involved in transactions conducted through our website;
other service providers or business partners associated with our products and/or services (including, but not limited to, insurance companies and/or healthcare providers offering services to our employees);
professional advisors and external auditors, including legal advisors, financial consultants, and other professional service providers;
government authorities, both within and outside the jurisdiction of the Republic of Indonesia, in accordance with applicable laws and regulations; and/or
relevant parties which are directly related to the provision of our Services under the applicable laws and regulations of Indonesia.
Where Personal Data is not required to be associated with you, We will take reasonable measures to anonymize or de-identify such data before disclosing or sharing it.
PROTECTING YOUR PERSONAL DATA
Data Security
We highly value your Personal Data and/or Transactional Data and make every reasonable effort to protect it. While We continuously strive to enhance the security standards of Our Services, We are not responsible for any loss or damage to your Personal Data and/or Transactional Data that occurs beyond Our control. We strongly advise you to regularly update your account and software, and to refrain from disclosing your account password for the Site to any party.
By providing your express consent, you authorize us to transmit, store, use, and/or process your Personal Data and/or Transactional Data on servers located at data centers designated by us. These data centers may be managed by third-parties and/or located within or outside the territory of the Republic of Indonesia. Nonetheless, the processing and use of your Personal Data and/or Transactional Data in connection with Our Services shall continue to be governed by this Privacy Policy and in compliance with applicable laws and regulations.
We remain fully committed to protecting your Personal Data. We implement appropriate technical measures to help safeguard the security of your information; however, please understand that no system can be entirely secure.
Data Retention
We retain your Personal Data for legitimate and essential business purposes, which include but are not limited to maintaining our Services, making informed business decisions, fulfilling legal obligations, resolving disputes, and managing access to our Services and related data. We may retain part or all of your Personal Data and/or Transactional Data for a minimum period of five (5) years, or for a longer duration as required by the prevailing laws and regulations of Indonesia and/or in according to Our policy, or until a specific request for deletion of your Personal Data is submitted by you.
Upon your request, We will delete your Personal Data so that it no longer identifies you, unless We are legally permitted or required to retain certain information or to store data in an anonymized or pseudonymized form, including but not limited to the following situations:
when We must retain Personal Data to fulfill our legal obligations, including but not limited to obligations related to taxation, auditing, or compliance with applicable law, we will retain the necessary information for the legally mandated duration; and/or
when retention is required for our legitimate business interests, such as preventing money laundering, improving Our products and/or services (including Company’s employee services), and/or ensuring the security of Personal Data.
Please note that some portions of your Personal Data may continue to be retained and/or controlled by other parties, including government institutions, through specific means. In the event that We share your Personal Data to authorized government institutions and/or other parties designated by the government or in collaboration with Us, you acknowledge and agree that the retention of such data will be subject to the respective data retention policies of those institutions.
YOUR RIGHTS AS A USER
Your Legal Rights
You may have certain rights under the applicable laws and regulations to request access to, correction of, and/or deletion of your Personal Data that is within our possession and/or control.
We may, however, refuse your request for access, correction, and/or deletion of part or all of your Personal Data if such refusal is permitted or required under the applicable laws and regulations. This includes circumstances where the Personal Data contains references to other individuals or where the request for access, correction, or deletion is deemed irrelevant, frivolous, vexatious, or associated with a potential violation of our terms and conditions or applicable laws.
In accordance with applicable regulations, We reserve the right to impose a reasonable administrative fee for any request for access and/or correction.
ADDITIONAL NOTES
Governing Law
This Privacy Notice shall be governed by and construed in accordance with the laws of the Republic of Indonesia. Any disputes arising from or in connection with this Privacy Notice shall be settled through the East Jakarta District Court.
Websites and Other Services
Our Services may contain links to websites operated by third-parties. The processing of Personal Data on such websites is entirely controlled and managed by the respective third-parties and remains their sole responsibility.
By choosing to access any third-party website, you acknowledge and agree that your use of such websites is subject to their respective terms and conditions as well as their privacy notices. Accordingly, We assume no responsibility for the terms, conditions, or privacy notices of those third-party websites. We strongly encourage you to review their terms and privacy notices to understand how your Personal Data is collected and used by them.
Any advertisements displayed on Our Services or within our Marketing Materials (as defined below) may function as links to the advertiser’s websites. Therefore, any data collected based on your access to such links will be collected and used by the relevant advertiser in accordance with their own privacy policies.
Marketing and Promotional Materials
We, and/or relevant third-parties associated with us for commercial and/or non-commercial purposes, may send you direct marketing, advertisements, or promotional communications through push notifications, in-app messages, postal mail, chat platforms, social media, and email (“Marketing Materials”), if you have subscribed to Our mailing list and/or agreed to receive Marketing Materials or promotional communications from Us.
You may opt out of receiving such marketing communications at any time by clicking the “unsubscribe” link included in the relevant message, using the relevant available opt-out method provided through the promotional medium, or by contacting Us using the contact details provided below.
Please note that even if you choose to unsubscribe from Marketing Materials, we may still send you non-promotional communications, such as account-related information, receipts, or administrative notices.
Updates to This Privacy Notice
We may, at our sole discretion, review and amend this Privacy Notice from time to time to ensure it remains consistent with Our future developments and/or with any changes in applicable laws and regulations in Indonesia. If We make any changes to this Privacy Notice, we may notify you through our official communication channels (as applicable). You agree that it is your responsibility to review this Privacy Notice periodically to stay informed of the latest updates regarding Our data processing and protection practices and that by continuing to use Our Services, communicate with Us, or access and use Our Services following any changes to this Privacy Notice, you shall be deemed to have agreed to and accepted this Privacy Notice and any of its amendments.