Privacy Policy

 

INTRODUCTION

 

Welcome to the Pulo1000 platform operated by PT. PBDigital Technology Indonesia (also called as “Pulo1000” or “we”). Pulo1000 takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all users of the Pulo1000 platform (“Platform”) (Platform and services provided by us and explained on our site collectively called as “Services”). We acknowledge the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to help you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to help you to make a decision before providing us with any of your personal data.

 

"Personal Data" or "personal data" means data, whether it is true or not, regarding an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information.

 

By using our Services, registering an account to us, visiting our Platform, or accessing our Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on our Platform. We reserve the right to amend this Privacy Policy at any time.

 

This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.

 

This Privacy Policy applies to Travellers as the buyer and business owner as the seller who use our Services unless we state expressly otherwise. 

 

WHEN WILL PULO1000 COLLECT PERSONAL DATA?

 

We will/may collect personal data about you:

    • when you register and /or access our Services or Platform, or access an account with us;
    • when you submit any application form, including, but not limited to, application forms or other forms relating to our product and services, either online or hardcopy;
    • when you make an agreement or provide us with any documentation or information regarding your interaction with us, or when you use our product and services;
    • when you interact with us, such as by telephone (which may be recorded), letters, facsimiles, face-to-face meetings, social media platforms and email, including when you interact with our customer service agent;
    • when you use our electronic services, or interact with us by our application or use our services on our Platform. This is including, but not limited to, by cookies which we may use when you interact with our application or website;
    • when you give permission to your device to share any information to our application or Platform;
    • when you link your Pulo1000 account to your social media or any other external account or use any other social media feature, in accordance with provider’s policy;
    • when you make transactions through our services;
    • when you submit criticism, suggestion or complaint to us;
    • when you register to any contest; or
    • when you submit your personal data to us for any reason

The list above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

 

WHAT PERSONAL DATA WILL PULO1000 COLLECT?

 

The personal data that Pulo1000 may collect includes but is not limited to:

    • name;
    • email address;
    • identity card or passport
    • date of birth;
    • billing address;
    • bank account number and payment information;
    • phone number;
    • gender;
    • any information sent by or connected to device (or devices) which is used to access our Services or Platform;
    • any information regarding your contacts, people and accounts which interact with you;
    • any photos, including photos taken for the purpose of electronic proof of delivery or audio and video recordings;
    • government-issued identification or any information required for our due diligence, regarding your customer, identity verification, or for the purpose of fraud prevention;
    • any information regarding the Users when they make a registration to use our Services or Platform, and when the Users access Services or Platform, and any information related to how the Users access/use our Services or Platform;
    • any information or data related to any parties or individual who have not registered yet on the Platform which are given by the Users during using Services; and
    • all data containing content which is used by the Users.

 

You agree not to submit any inaccurate information or misleading, and you agree to inform the inaccuracies or information changes.

We have right on our policy to require further documentation for verification purpose of the information provided to us.

In some cases, you provide any information or data related to third parties or individual who have not registered yet on the Platform at the time of using Services, then you represent and guarantee that you have already got any necessary approval, license and permission from data or information owner to share and proceed the personal data to us and for us to collect, store, use and disclose those data according to Privacy Policy.

 

When you register to be a user of our Platform by using your social media account (“Social Media Account”), connecting your Pulo1000 account with your social media account or using every social media feature, we can access your personal information that you voluntarily submit to the Social Media Account provider according to their policy, and we will organize and use that personal information according to this policy all the time.

 

To ensure the security of buyer’s personal data, Pulo1000 will disguise and/or hide buyer’s Personal Data for (i)any unpaid order, (ii) any cancelled order, or (iii) any completed order. For completed orders, Pulo1000 will disguise and/or hide Personal Data in 61 days after the order has been completed.

 

You have the right to access, repair, change and or delete Personal Data/Information that you have provided and have been stored in our system by contacting our customer service and/or through the features found in our application. 

We reserve the right to refuse your request to access, correct or delete some or all of your Personal Data/Information that we store or control as long as permitted or required by applicable law. This may include circumstances where your Personal Data contains a reference to another individual or where a request to access, correct or delete it is for reasons that we deem to require disproportionate technical effort or may pose an operational risk.

However, for your attention, by withdrawing your consent to our further collection, use or disclosure of information at any time in the future, it may affect to the use of our Services and Platform. For example, by making a cancellation on location information collection, it may cause location-based features to be disabled.

 

OTHER DATA COLLECTION

 

In most of web and mobile applications, your device will send any information that may include your personal data/information which may be recorded by web server when you use our Platform. We will collect information about your computer or any media you use, including your IP address, operating system, browser used, URL, page, geographic location and access times as well as other data related to your use of your computer and recorded when you use our online Services (“IP Details”).

 

“Cookies” are text files containing small amount of information downloaded to your computer or device which record any data about your computer or device, how and when the Services or the Platform being used or visited, how many people access, and any other activities in our Platform.

“Cookies” are used for various reasons, such as tracking your transactions with our partners, remembering your preferences and generally improving your experience when using a website.

You can refuse of using “Cookies” by setting your browser to accept or not to accept a cookie.

 

HOW DO WE USE ANY INFORMATION THAT YOU PROVIDE TO US?

 

Any information that you provide to us will be stored and only used by us for the purpose of providing our products and services to you, namely for the purposes of accounting, billing, auditing, payment verification, news, and security, administrative and legal purposes, testing, system maintenance and development, customer relations, promotions and other actions we deem necessary to assist us in the future in providing services to you, such as:

    • to process your application / transaction with us or your transaction and communication with third party through the Services;
    • to manage, operate and provide your use of and / or access to our Services and Platform (include, not limited to, reckon your preferences), as well as your account related to us;
    • to process your transactions, manage and expedite the process of using the Online Services, as well as other purposes as long as permitted by applicable laws and regulations;
    • to apply Services Requirements or License Agreement for end users;
    • to protect personal safety and rights or other party’s safety;
    • to identify, verify, due diligence or know customer’s purpose;
    • to maintain and deliver every update on software and / or other updates, as well as support that may be needed from time to time to ensure the success of our Services;
    • to facilitate a customer service, response to your complaint or report, answer your question;
    • to contact or communicate with you by phone, text messages and / or facsimiles, email and / or any other means in order to maintain our relation / communication, but not limited to, maintain communication regarding the administration related to our Services; 
    • to enable other users can interact / connect with you or view some of your activities on the Platform, including notify you when other users have already been sent personal messages to you, post comments for you on the Platform or connect with you by social features on the Platform;
    • to conduct research activities, analysis and development (including, not limited to, data analysis, surveys, product and service development and / or profiling), analyse how you use our Services, to improve our Services/ products and / or improve your customer experience;
    • to allow audit and survey, such as, validation of our audience composition and size, as well as acquaint their experience with Pulo1000’s Services;
    • to collect other information for Social Media marketing purposes using direct and open graphic techniques and for conventional digital marketing purposes, such as sending you push notifications, including but not limited to via electronic mail, WhatsApp, and through social media (such as YouTube, Instagram, Facebook, Twitter, Tiktok, Line, Tumblr, Telegram, Reddit, Snapchat, LinkedIn, and etc) to notify you of new product information, special offers or other information that we think it will interest you;
    • to use all information that we receive to protect ourselves against all claims and applicable laws related to the use of Services and violations that you commit on our Platform for all provisions as stipulated in Pulo1000 terms of use and guidelines for the use of our products and services, including but not limited to if required by order of the Court in legal proceedings; 
    • to use your Personal Data for investigation of suspicious transactions or transactions indicated to contain elements of fraud or violations of Pulo1000 terms of use and guidelines for the use of our products and services as well as applicable legal provisions, as well as take necessary action to address it;
    • to use the information that we receive when we carry out a merger, sale of company assets, consolidation or restructuring, financing or acquisition for our company;
    • to verify your data by enabling you to upload or share the necessary information from your mobile phone and enhancing your experience on our Services including but not limited to refund process, insurance claim, booking and cancellation;
    • to publish your reviews related to our Services and / or products;
    • just to inform you that we will notify you when we collect any Personal Data/Information for any other purposes.

 

HOW DO WE SHARE PERSONAL DATA THAT WE COLLECT?

 

For the purposes of transactions and Services, the Personal Data which you provide to us through our Services will be collected and can be used and shared to third parties who cooperate with us.

 

Disclosures of Personal Data to our third parties service providers, agents and / or affiliates or related companies in and / or outside the territory of Indonesia require a legal basis and compliance with applicable laws. To ensure that third parties, agents and / or affiliates or related companies outside the territory of Indonesia, we have cooperated with, provide a level of protection proportionate with our commitments in this Privacy Policy, we will use the efforts that a reasonable person in the position of promisor would use so as to achieve that goal as expeditiously as possible, but does not include: incurring any expenses not expressly contemplated by the Agreement including.

 

 

HOW DO WE RETENT PERSONAL DATA THAT WE COLLECT?

 

We are concerned about privacy issues, so that retention of personal data is necessary to fulfil the purpose for which it was collected and will be done by permission of law. In case your Personal Data are shared to authorized government agencies and / or other third parties appointed by government authorities or cooperate with us, each party’s policy regarding data storage should be followed concerning the storage of your Personal Data by related parties and it is agreed and acknowledged by you.

 

In case your Personal Data are shared to authorized government institutions and / or other institutions appointed by government authorities, you agree and acknowledge that your Personal Data are retained by the third party and / or relevant institutions by following their respective policy on data retention. It should be noted that we have no responsibility regarding their policy on data retention and shall not be liable for any such retention of your Personal Data. 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 third party’s retention of your Personal Data.

 

HOW DO WE SECURE YOUR PERSONAL DATA?

 

Your security of Personal Data is very important for us. Pulo1000 takes reasonable steps which is designed to protect your Personal Data. As we have known, no data transmission over the Internet or storage of information is 100% secure. Of course, we will use all reasonable efforts to protect and secure your Personal Data against access, collection, use or disclosure by unauthorized persons and against unlawful processing, accidental loss, destruction and damage or similar risks. But again, you have to do so at your own risk.  You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Data is no longer secure, please promptly notify us at contact@pulo1000.com.

 

CHANGES TO THIS PRIVACY POLICY

 

Pulo1000 will update this Privacy Policy from time to time as it deems necessary in its sole discretion without prior notice. Pulo1000 encourages you to periodically check this policy. By continuing to access and use Our Online Services, you are deemed to agree to changes that may exist in this Privacy Policy.

The “LAST UPDATED” legend at the bottom of this page indicates when this Privacy Policy was last revised.

 

CONSENT

 

You acknowledge that any Personal Data provided to us is valid and true. By reading all of these terms, accessing and using our Services, you are deemed to have been notified, read, understood, agreed, and stated that you are subject to this Privacy Policy and the changes that we may make from time to time.

You can withdraw your consent by contacting our customer service.

 

ADVERTISING

 

Pulo1000 cooperates with third parties to promote and create attractive advertisements for you based on the use of our Services which we complete from the data you use on our Services. “Cookies” may also be used by the company we cooperate to track customer behaviour. These companies may use your information to disclose about user behaviour to provide customized advertising across various services and products. In providing products and services, each company uses cookies in accordance with privacy information in accordance with the privacy and security policies of each company.

 

HOW TO CONTACT US

 

If You have any questions or need further information, you can contact our Customer Service or send an email to contact@pulo1000.com

 

APPLICABLE LAW

 

The use of this Online Services is subject to and governed by and or interpreted in accordance with applicable law in Indonesia, without affecting the principles of conflict of law that apply.

 

Last updated: September 22, 2022