The following Privacy Policy describes how we, Klikoo (PT Pintar Ventura Pertama and affiliates, "we" or "Klikoo") collect, store, use, process, retain, transfer, disclose and protect your Personal Information. This Privacy Policy applies to all users of our applications, websites (http://klikoo.co.id), services, or products ("Application"), unless otherwise covered by a separate privacy policy. Please read this Privacy Policy thoroughly to ensure that you understand our data processing practices. Unless otherwise defined, all capitalized terms used in this Privacy Policy shall have the same meaning ascribed to them in the Terms of Use of Klikoo. This Privacy Policy includes the following matters:

1. Personal Information which we collect
2. The use of Personal Information which we collect
3. Sharing of Personal Information which we collect
4. Storage of Personal Information
5. Access and correction of Personal Information
6. Cross Border Data Transfer
7. Security of your Personal Information
8. Changes to this Personal Information
9. Acknowledgment and consent
10. Marketing and promotional material
11. Anonymous Data
12. Third party platforms
13. Severability
14. How to contact us

1. PERSONAL INFORMATION WHICH WE COLLECT

We collect information which identifies or can be used to identify, contact, or locate the person or device to whom that information pertains ("Personal Information"). Personal Information includes, but not limited to, name, address, date of birth, age, occupation, phone number, cell phone number, e-mail address, bank account, gender, identification (including KTP, SIM, or Passport) or other government issued identifier, photo, nationality, phone number of our Applications users and non-users in your mobile phonebook, health data, financial related information, and biometric information (including but not limited to facial recognition). Additionally, to the extent other information, including a personal profile, and/or unique identifier, is associated or combined with Personal Information, then that information is also considered as Personal Information. The Personal Information which we collect may be provided by you directly or by third parties (for example: when you register or use the Application, when you contact our customer services, or you otherwise provide Personal Information to us). We may collect information in various forms and purposes (including purposes permitted under prevailing laws). Information we obtained from you or from your mobile device directly

1. When you register and create an Account by using the Application, you have to provide to us certain Personal Information, including your name, physical address, e-mail address and your phone number.
2. When you use the Application, you have to provide us with additional information as may reasonably be required by us in order for the Application to work, for example If you are using the Application as a user, you will need to provide us with information as to the type of service you seek and use in the Application.

Information collected whenever you use the Application or visit our website

1. Whenever you use the Application or visit our website, we may collect certain technical data concerning your usage such as, internet protocol (IP) address, information as web pages previously or subsequently viewed, duration of every visit/session, the internet device identity (ID) or media access control address, mobile advertising ID and other device information including information regarding the manufacturer, model and operating system of the device that you use to access the Application or our website.
2. Whenever you use the Application or visit our website, certain information may also be collected on an automated basis using cookies. Cookies are small application files stored on your computer or mobile device. We use cookies to track user activity to enhance user interface and experience. Most mobile devices and internet browsers support the use of cookies; but you may adjust the settings on your mobile device or internet browser to reject several types of certain cookies or certain specific cookies. Your mobile device and/or browser would also enable you to delete whatever cookies have previously been stored. However, doing so may affect the functions available on the Application or our website.
3. Whenever you use the Application through your mobile device, we will track and collect your geo-location information in real-time. In some cases, you will be prompted or required to activate the Global Positioning System (GPS) on your mobile device to make it easy when choosing the location for goods delivery or the delivery fee, as well as to enable us to give you a better experience in using the Application. You can always choose to disable the geo-location tracking information on your mobile device temporarily. However, this can affect the functions available on the Application.

Information Collected from third parties
We may also collect your Personal Information from third parties (including our agents, vendors, suppliers, contractors, partners and any others who provide services to us, collect Personal Information on our behalf, or whom we collaborate with). In such cases, we will only collect your Personal Information for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be). Information about third parties you provide to us

You may provide us with Personal Information relating to other third-party individuals (including Personal Information relating to your spouse, family members, friends, or other individuals). You will, of course, need their consent prior to do so – see "Acknowledgement and Consent", below, for further information.

2. THE USE OF PERSONAL INFORMATION WHICH WE COLLECT

We may use Personal Information collected for any of the following purposes as well as for such other purposes as are permitted by applicable law ("Purposes"):

1. to identify you and to register you as a user and to administer, verify, deactivate, or manage your Account;
2. to facilitate or enable any verification which based on our discretion it is necessary before we register you as a user, including performing Know Your Customer (KYC) process;
3. to process and facilitate orders and payment transactions made by you;
4. to notify you of any transaction or activities in the Application or other system connected to our Application;
5. to communicate with you and to send you information in connection with the use of the Application;
6. to notify you of any updates to the Application or changes to the services available;
7. to process and respond to enquiries and feedback received from you;
8. to maintain, develop, test, enhance and personalize the Application to meet your needs and preferences as a user;
9. to monitor and analyse user activities, behaviour, and user demographic data including trends and usage of various services available on the Application;
10. to offer or provide services from our affiliates or partners;
11. to send you direct or targeted marketing communications, advertisement, vouchers, surveys, and information on special offers or promotions.
12. to undertake associated business processes and functions;
13. to monitor usage of the Application and administer, support and improve the performance efficiency, growth, user experience and the functions of the Application;
14. to provide assistance in relation to and to resolve any technical difficulties or operational problems with the Application or the services;
15. to generate statistical information and analytics data for the purpose of testing, research, analysis, product development, commercial partnership, and cooperation;
16. to prevent, detect and investigate any prohibited, illegal, unauthorized or fraudulent activities;
17. to facilitate business asset transactions (which may be in the form of mergers, acquisitions, or asset sales) involving us and/or any of our affiliates; and
18. to enable us to comply with our obligations under any applicable law, (but not limited to responding to regulatory requests, investigations or directives) and conducting audit checks, due diligence and investigations.

3. SHARING OF PERSONAL INFORMATION WHICH WE COLLECT

a. We may disclose to or share with affiliates and other parties your Personal Information for any of the following purposes as well as for such other purposes as are permitted by applicable law:

1. to enable the provision or rendering of services to you;
2. if required or permitted by applicable law (including but not limited to responding to regulatory enquiries, investigations or directives, or complying with statutory or regulatory filing and reporting, and licensing requirements), for the purpose as specified in the prevailing laws and regulations;
3. if instructed, requested, required or permitted by the government authorities, for the purpose as specified in the government policy, regulations or prevailing laws and regulations;
4. if there is any form of legal proceeding between you and us, or between you and another party, in connection with, or relating to the services, for the purposes of the said legal proceeding;
5. in relation to all verification process which we or the service provider consider necessary before we register you as user;
6. in an emergency concerning your safety (whether you are a user or a service provider) for the purposes of dealing with such emergency;
7. in a situation concerning your health or public interest (whether you are a user or a service provider), we may share your Personal Information to the government authorities and/or other institutions that may be appointed by the government authorities or have a cooperation with us, for the purposes of contact tracing, supporting government initiatives, policies or programs, public safety and any other purposes reasonably needed;
8. in connection with, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into another company, for the purposes of such a transaction (even if the transaction is eventually not proceeded with);
9. to third parties (including our agents, vendors, suppliers, contractors, partners and any other parties who provide services to us or to you, perform duties on our behalf, or whom we enter into commercial collaboration with), for or in connection with the purposes for which such third parties are engaged, to perform disclosure to the relevant third parties which are technically required to process your transaction or for the purposes of our collaboration with such third parties (as the case may be), which may include allowing such third parties to introduce or offer products or services to you, authenticate you or connect with your Account, or conducting other activities including marketing, research, analysis and product development; and
10. in the event we share Personal Information with affiliates, we will do so for the purpose of them helping us to provide the Application, to operate our business (including, where you have subscribed to our mailing list, for direct marketing purposes), or for the purpose of data processing on our behalf. For example, a Klikoo Affiliate in another country may process and/or store your Personal Information on behalf of the Klikoo in your country. All of our affiliates are committed to processing the Personal Information that they receive from us in line with this Privacy Policy and prevailing laws and regulations.

b. When it is not necessary for the Personal Information to be associated with you, we will use reasonable endeavors to remove the association of the Personal Information with you as an individual before disclosing or sharing such information.
c. We will not sell or lease your Personal Information.
d. Other than as provided for in this Privacy Policy, we may disclose or share your Personal Information if we notify you and we have obtained your consent for the disclosure or sharing.

4. STORAGE OF PERSONAL INFORMATION

1. Your Personal Information will only be held for as long as it is necessary to fulfill the purpose for which it was collected, or for as long as such retention is required or permitted by prevailing laws and regulations. We shall cease to retain Personal Information, or remove the means by which the Personal Information can be associated with you as an individual, as soon as it is reasonable to assume that the purpose for which that Personal Information was collected is no longer being served by retention of Personal Information and retention is no longer necessary for legal or business purposes.
2. Please note that there is still the possibility that some of your Personal Information might be retained by the other party, including by the government institutions in certain manner. In the event we share your Personal Information to the authorised government institutions and/or other institutions that may be appointed by the government authorities or have a cooperation with us, you agree and acknowledge that the retention of your Personal Information by the relevant institutions will follow their respective policy on data retention. Information conveyed through communications between users and service providers made other than through the use of the Application (such as by telephone calls, SMS, mobile messaging or other method of communication) may also be retained by some ways. We do not allow the retention of Personal Information by such means and we have no responsibility to you for the same. We shall not be liable for any such retention of your Personal Information. You agree to indemnify, defend and release us, our officers, directors, employees, agents, partners, suppliers, contractors and Affiliates from and against any and all claims, losses, liabilities, expenses, damages and costs (including but not limited to legal costs and expenses on a full indemnity basis) resulting directly or indirectly from any unauthorised retention of your Personal Information.

5. ACCESS AND CORRECTION OF PERSONAL INFORMATION

1. Subject to the prevailing laws, you may request us for access to and/or the correction of your Personal Information in our possession and control, by contacting us at the details provided below.
2. We reserve the right to refuse your requests for access to, or to correct, some or all of your Personal Information in our possession or control if permitted or required under any applicable law. This may include circumstances where the Personal Information may contain references to other individuals or where the request for access or request to correct is for reasons which we reasonably consider to be trivial, frivolous or vexatious

6. CROSS BORDER DATA TRANSFER

1. Your Personal Information which we collect may also be stored, transferred or processed by third party. We will use all reasonable endeavors to ensure that all such third party service providers provide a level of protection that is comparable to our commitments under this Privacy Policy
2. We will comply with all prevailing laws and regulations and to use all reasonable endeavours to ensure our Affiliates in other countries and all third party service providers provide a level of protection that is equal to our commitments under this Privacy Policy.

7. SECURITY OF YOUR PERSONAL INFORMATION

Confidentiality of your Personal Information is of utmost importance to us. We will use all reasonable endeavours to protect and secure your Personal Information against access, collection, use or disclosure by unauthorised persons and against unlawful processing, accidental loss, destruction and damage or similar risks. However, the transmission of information through the Internet is not completely secure. Although we will do our best to protect your Personal Information, you acknowledge that we cannot guarantee the integrity and accuracy of any Personal Information which you transmit over the Internet, nor guarantee that such Personal Information would not be intercepted, accessed, disclosed, altered or destroyed by unauthorised third parties, due to factors beyond our control. You are responsible to keep your Account details confidential including your password with anyone and you must always maintain and fully responsible for the security of the device that you use.

8. CHANGES TO THIS PRIVACY POLICY

We may review and amend this Privacy Policy at our sole discretion from time to time, to ensure that it is consistent with our future developments, and/or changes in legal or regulatory requirements. If we decide to amend this Privacy Policy, we will notify you of any such amendments by means of a general notice published on the Application and/or website, or otherwise to your e-mail address set out in your Account. You agree that it is your responsibility to review this Privacy Policy regularly for the latest information on our data processing and data protection practices, and in the event you continue using the Application or website, communicating with us, or accessing to and using the services following any amendments to this Privacy Policy will constitute your acceptance to this Privacy Policy and all of its amendments.

9. ACKNOWLEDGMENT AND CONSENT

1. By agreeing the Privacy Policy, you acknowledge that you have read and understood this Privacy Policy and you agree all of its terms. In particular, you agree and consent to us collecting, using, sharing, disclosing, storing, transferring, or processing your Personal Information in accordance with this Privacy Policy.
2. In circumstances where you provide us with Personal Information relating to other individuals (such as Personal Information relating to your spouse, family members, friends, or other parties), you represent and warrant that you have obtained such individual's consent for, and hereby consent on behalf of such individual to, the collection, use, disclosure and processing of his/her Personal Information by us.
3. You may withdraw your consent to any or all collection, use or disclosure of your Personal Information at any time by giving us reasonable notice in writing using the contact details stated below. You may also withdraw your consent for us to send you certain communications and information through any "opt-out" or "unsubscribe" facility contained in our messages to you. Depending on the circumstances and the nature of the consent which you are withdrawing, you must understand and acknowledge that after such withdrawal of consent, you may no longer be able to use the Application or services. A withdrawal of consent by you may result in the termination of your account or of your contractual relationship with us, with all accrued rights and obligations remaining fully reserved. Upon receipt of your notice to withdraw consent for any collection, use or disclosure of your Personal Information, we will inform you of the consequences which might be occur from such withdrawal so that you can decide if indeed you wish to withdraw consent.

10. MARKETING AND PROMOTIONAL MATERIAL

We and our partners may send you direct marketing, advertisement, and promotional communications through push-notification app, message in Application, post, telephone call, short message service (SMS), WhatsApp or other chat platforms, social media, and e-mail ("Marketing Materials") if you have agreed to subscribe to our mailing list, and/or consented to receive marketing and promotional materials from us. You may choose to stop receiving such marketing communications at any time by clicking on any "unsubscribe" facility embedded in the relevant message, or otherwise contacting us using the contact details stated below. Please note that if you choose to unsubscribe, we may still send you non-promotional messages, such as ride receipts or information about your Account.

11. ANONYMOUS DATA

We may create, use, license or disclose Personal Information, that are available, however, (i) that all things which can do identification have been removed so that the data, alone or in combination with other available data, cannot be linked to or associated with or cannot identify any person, and (ii) that the similar data has been combined so that the original data forms a part of a larger data set.

12. THIRD PARTY PLATFORMS

1. The Application, website, and Marketing Materials may contain links to websites that are operated by third parties. We do not control nor accept liability or responsibility for these websites and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. Please read the terms and conditions and privacy policies of those third-party websites to find out how they collect and use your Personal Information.
2. Advertisements contained on our Application, website, or Marketing Materials operate as links to the advertiser's website and as such any information they collect by virtue of your clicking on that link will be collected and used by the relevant advertiser in accordance with the privacy policy of that advertiser.

13. SEVERABILITY

If any of term under this Privacy Policy is declared invalid, illegal or unenforceable by law and the other public policies with any reasons whatsoever, that unenforceability shall only be limited to the invalid terms and unenforceable and the remaining terms under this Privacy Policy are still fully valid.

14. HOW TO CONTACT US
If you have any questions regarding this Privacy Policy or if you would like to obtain access and/or to correct or update your Personal Information, please contact cs.klikoo@pvg.co.id.