Privacy Notice

KarmaClub is committed to protecting personal data. We believe that you can make the right decision regarding disclosure of your personal data by reading this Privacy Notice (“Privacy Notice”). This Privacy Notice explains how and why  KarmaClub and its Affiliates (“KarmaClub”, “We”, “Our”, or “Us”) obtain, collect, and use your personal data, also provides information about rights to personal data and to whom we share your personal data (“Process” or “Processing” ).

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The data controllers of your personal data is KarmaClub. This Privacy Notice applies to personal data provided to us, both directly by you or as identified through the use of our Electronic Systems and/or Services. We may use personal data provided to us for any of the purposes described in this Privacy Notice.

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Personal data is as defined by the prevailing laws regarding personal data. Personal data may include information and data about you that are personally identifiable, which you provide or collected through Electronic Systems and/or Services, including, but not limited to your name, phone number, address, electronic mail (e-mail) address, and other information as well as records of your activities while accessing and using the Electronic Systems that might identify you.

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By accessing and using the Electronic Systems and providing your personal data to us, you acknowledge you have read this Privacy Notice, and, to the extent your consent is necessary and valid under applicable law, you consent to the collection, use, and disclosure of your personal data to KarmaClub and any third party recipients in accordance with this Privacy Notice.

1. ‍LEGAL BASIS OF PERSONAL DATA PROCESSING‍

We process your personal data if one or more conditions applies:

• You verified your personal data and consent to us the processing of your personal data for purposes as described in this Privacy Notice;
• We are obliged to fulfill our obligations based on our agreement/contract with you;
• We are obliged to fulfill our obligations from any requirements of law under the applicable laws;
• We are obliged to protect your vital interests;
• We are obliged to perform any obligations for public interests, public service or exercise of our authority under the applicable laws;
• Based on any legitimate interest and to the extent permitted by law, we have to process your personal data with due consideration to the purpose, needs, and our balanced interests.

2. COLLECTION OF YOUR PERSONAL DATA

This section will describe the types and/or categories of personal data that we may collect and the sources for which such data is collected. We may obtain personal data with the following categories:

1. Data Collected When You use the Electronic System

• We may collect your personal data when you access and use the Electronic System, which may allow us to identify or be able to identify, contact, determine the location of you or the device you are using. We collect personal data which you provided and verified to us in order to provide Services for you. Such personal data is including, but not limited to: name, electronic mail, telephone number and/or other information needed to provide our Services to you. Do not provide your personal data to us, unless you consent to our use of such personal data for any purposes as described in this Privacy Notice.

• We may also collect any of your personal data when you participate in events and/or meetings that we organize, such as seminars, contests or award programs, in any form including photos, video recordings and your voice. We may also use this data and/or include it in our communications, publications, advertisements and/or promotions. 

2. Technical Data Collected When You use the Electronic System

To ensure the Electronic System is managed well, we may collect your personal data when you use or access the Electronic System in the form of technical data such as your internet protocol address, the web pages you have visited, the internet browser you have used, the web pages you have previously and subsequently visited and the duration of each visit. visits or sessions that allow us to deliver Electronic System functions. Technical information will also include:

• Information Log: When you use Electronic Systems, we may collect information called “log information”. This information may include your IP address, browser type, operating system, nationality, web pages you visited, your communications provider, device information, search history and other information related to your internet usage. ‍
• Cookies and similar technologies: Cookies are small data files that your browser places on your internet device. With cookies, the features of the applications and/or websites you access can store information or remember your actions and preferences over time. Most browsers and internet devices support cookies; however you can set the browser or device you are using to refuse certain types of cookies or specific cookies. In addition, you can delete cookies at any time. We use cookies for various purposes. We use it, for example, to remember your page browsing preferences, help you use the Service or administer the Service.

3. Data Collected from Third Parties

We may obtain your Personal Data from publicly available sources including but not limited to agents, vendors, partners and other parties who provide services to us, perform tasks on our behalf, or with whom we will work together. In such cases, the collection of personal data will be carried out after an acknowledgment or order from you; and we will only collect your personal data for or in connection with the purposes involving such third parties or the purposes of our cooperation with such third parties (depending on the situation). 

4. Third Party Data You Provided to Us

We may collect data or information of third parties that is data of your company/business, including the name, social media, and your business telephone number. The data we collect and process are to provide Services to you. By providing the data and information of your company/business, you guarantee that you have obtained prior approval from your company/business to provide its data to us.

5. Children’s Privacy Protection

We understand the importance of protecting children’s personal data. Electronic System is not targeted to be used by children under the age of 18 (eighteen). We will not intentionally collect and/or use children’s personal data under the age of 18 (eighteen). If you are under 18 (eighteen) years old, do not provide your personal data to us. If you unintentionally provide your personal data, please inform your parents or guardians to inform us and we will delete your personal data. 

3. USE OF YOUR PERSONAL DATA

In order to provide Services to you and continuously improve the services and user experience on our Electronic Systems, we may process your personal data, to the extent permitted by applicable law, for the following purposes:

• to communicate with you in connection with the use or management of the Services and to provide you with information about the Services and Electronic Systems.

• to send messages, changes and/or general updates to the Services and Electronic Systems, special offers or promotions, respond to questions and suggestions received from you and provide assistance in connection with and to resolve technical difficulties or operational problems with the System Electronics or Services.

• to manage the operation of our Electronic System to improve Services provided in the Electronic System.

• Detect and prevent activities related to criminal acts, fraud, abusive acts and other actions that we consider to be detrimental to our interests and/or Electronic System users.

• For the purposes of Services development and other purposes that we convey to you when we collect personal data.

4. TRANSFER OF PERSONAL DATA

We may transfer or disclose your personal data to companies, organizations, government institutions and individuals including our subsidiaries and affiliates (each a “Third Party”), for the purposes of as follows and other purposes permitted under applicable law:

• If you are to facilitate and enforce the activities you carry out through the Electronic System;
• To Third Parties who have direct or indirect relationships with government institutions for any purposes related to law enforcement suspected of involving you, as regulated in statutory provisions and other matters other according to the request of the relevant government institution in writing to us;
• to the extent that it is required by law, or necessary to comply with the provisions of laws and regulations, government agencies, or in the event of a dispute, or any form of legal process between you and us, or between you and other parties in connection with, or related to the Services, or in an emergency related to your health and/or safety;
• In connection with our actions to employ or cooperate with Third Party companies and individuals to facilitate or provide assistance for and/or on our behalf with the aim of providing consumer assistance, maintenance activities, management, and analysis of Electronic Systems and Services development; and/or
• For other purposes that are not stated in this Privacy Notice provided that we have obtained your consent before transferring such personal data.

A Third Party may appoint/use their own third party subcontractors that have access to personal data (sub-processors). Our policy is that the Third Party is obliged to require the same obligations with the personal data protection obligations instructed by us, to their sub-processors. 

We may remove certain parts of your personal data that can identify you or combine your personal data with other information in such a way (so that the information becomes anonymous data or is no longer associated with you) and discloses the anonymous data to Third Parties for Purpose of Services Development, database management, analysis or improvement of the Service. We do not guarantee the anonymity of the information we provide if the third party has obtained personal data from you and can associate and match the anonymous data we provide with data that you have and/or will provide to the third party. 

5. ACCESS TO PERSONAL DATA

When you provide your personal data to us, you must ensure that the information you provide is accurate and complete. If you believe that your personal data that we manage is inaccurate or incomplete, please immediately make changes to your personal data by contacting us via the contact details below. 

To the extent required by applicable law, you can ask us to access and/or correct your personal data which is in our possession and control, by contacting us at the contact details stated below or as informed by us from time to time on through the Electronic System.

We reserve the right to refuse your request to access, or to correct, some or all of your personal data in our possession or control if permitted or required under applicable laws. 

6. APPROVAL

By accessing the Electronic System and/or using the Services available on the Electronic System, you hereby expressly state that you have read, understand, understand and agree to the provisions of this Privacy Notice. In particular, you acknowledge and give consent to us to collect, use, share, disclose, store, transmit and process your personal data in accordance with this Privacy Notice.

From time to time, we may make changes to this Privacy Notice to comply with changes to applicable laws, our business activities, features on Electronic Systems, and/or further technology in Electronic Systems. In the event that we make changes to the way we collect and Process your Personal Data:

• We will notify you of such changes by means of a general notification on the Electronic System or your registered electronic mail;
• The changes will be published in our Electronic System with the effective date stated in this Privacy Notice or notification to you;
• By continuing to use the Electronic System, communication with us or use of our Services after the effective date of the change will act as your agreement to this Privacy Notice and all of its changes.

Unless otherwise stipulated by laws and regulations, you may withdraw your consent to the collection, use and/or disclosure of your personal data and/or destruction of your personal data, the terms and procedures of which are in accordance with the laws and regulations that specifically regulate this matter, by giving written notice to us from time to time through the Electronic System or through contact details below. Withdrawal of consent or destruction of your personal data, either partially or completely, may result in you no longer being able to use the Services and Electronic Systems. Even if you withdraw your consent, we can still archive and store your personal data if required by applicable law, including but not limited to data retention provisions. You hereby state that you understand and agree to the impact of withdrawal of consent and/or destruction of your personal data.

7. STORAGE AND RETENTION OF PERSONAL DATA

Subject to the terms of withdrawing your consent as stated in Point 6 above, we will keep your personal data to the extent it is necessary for the purposes of processing as described in this Privacy Notice, to provide Services in the Electronic System, for our legitimate business interests, and/or such storage is required under the applicable law.

Please note that there is still the possibility that some of your personal data is stored by other parties including by service providers, in certain ways. Information conveyed through communications between users and service providers conducted other than through the Electronic System (such as through telephone calls, SMS, cellular messages or other means of communication) may also be stored in several ways. We do not allow and encourage the storage of personal data in this way and we are not responsible to you for it. We will not be responsible for the storage of your personal data in such cases. You agree to indemnify, defend and hold harmless us, our officers, directors, employees, agents, partners, suppliers, contractors, and our affiliates from and against any and all claims, losses, liabilities, costs, damages and costs (including but not limited to (but not limited to legal fees and expenses indemnification in full) resulting directly or indirectly from any unauthorized storage of your personal data.

8. SECURITY OF YOUR PERSONAL DATA

The security and confidentiality of your personal data is important to us. Therefore, we will protect your personal data by making reasonable efforts and steps including physical and technical data security and organizational procedures to prevent unauthorized access to your personal data. However, it is important to remember that although there are safeguards that we have put in place, no electronic information is 100% secure and therefore we cannot fully guarantee the security of your personal data. You acknowledge that we cannot guarantee the integrity and accuracy of any personal data that you transmit via the internet, or guarantee that such personal data will not be intercepted, accessed, disclosed, altered or destroyed by unauthorized third parties, due to factors beyond our control.

9. LINK TO OTHER WEBSITE

Electronic Systems may contain links to other websites that are not controlled by us and do not operate under our Privacy Notice. When you link to third-party sites, our Privacy Notice no longer applies. Please note that we have no control over these other websites. Therefore, we do not accept any responsibility or liability for this website 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 data.

You understand, acknowledge and agree that you hold us harmless from any claim, responsibility or liability for the availability, accuracy, suitability, completeness or correctness of services, content, information or products provided or offered by such third parties. We do not make any representations or warranties about the services, content, information and/or products provided by third parties.

10. RIGHTS TO THE PERSONAL DATA

You may have certain rights based on applicable laws about your personal data that we process based on your consent in relation to the protection of personal data. In particular, you have rights to:

1. Obtain information about our identity, accountability, and legal basis to collect and/or use your personal data, and to obtain information about the purposes of the processing of your personal data as described in this Privacy Notice;
2. Complete, update, and correct mistakes or inaccuracy of your personal data;
3. Obtain access and copy of your personal data recorded in our Electronic System;
4. Ask us to end the processing of your personal data, delete and/or destruct your personal data, in the event that:

1. You withdraw your consent to the processing of your personal data;
2. Your personal data is no longer required for the purposes of the collection and processing of your personal data; and/or
3. You object to the processing of your personal data for direct marketing.

5. File an objection to the decision making act based on the automated processing which have legal consequences and significant impact to you;
6. Suspend or restrict the processing of your personal data based on the purposes of personal data processing as described in this Privacy Notice; and/or
7. Take legal action upon the breach of your personal data processing based on the applicable law.

You may perform your legal rights above towards your personal data, unless there are conditions that exclude or restrict your rights to the personal data based on the applicable law.

11. MISCELLANEOUS

This Privacy Notice is governed by and construed in accordance with the laws of the Republic of Indonesia. Any and all disputes arising from this Privacy Notice will be governed by the exclusive jurisdiction of the South Jakarta District Court.

We may update this Privacy Notice at any time by issuing the latest version updated herein. Therefore, we suggest that you review this Privacy Notice periodically to obtain information regarding your personal data protection.

This Privacy Notice is an integral part of the General Terms and Conditions and the agreement you signed with us in connection with the use of Services on the Electronic System.

12. DEFINITION

“Affiliates” means (i) the controlling party of; (ii) subsidiaries of; or (iii) a party that is under one control with; or (iv) parties who are in the same business group with Us. 

“You” means any party who uses the Service and/or visits or accesses the Electronic System. 

"Services" means the various services offered by us as an Electronic System provider. 

“Electronic System” means the electronic means that we use to provide information and services to you, including but not limited to http://www.karma.club, other sites, and/or applications and websites that we have officially developed to support the service ecosystem. 

“Services Development” means the intended use and disclosure of Personal Data for the purposes, including but not limited to: 

1. assess or understand the effectiveness of Our marketing promotions on Electronic Systems and to deliver relevant advertisements to you; 
2. make suggestions and recommendations to you about the Service or third party products and services that may be of interest to you; 
3. to maintain, develop, test, improve and personalize the Service to meet your needs and preferences; 
4. carry out activities related to the provision of services offered or issued by us or third parties collaborating with us and providing research reports or materials for analysis;
5. perform risk assessment, statistical and trend analysis and planning, including carrying out data processing, statistical analysis, credit, risk management and anti-money laundering, creating and managing assessment models and other backgrounds, and keeping a history of your and Relevant Individuals' activities for future reference this and in the future both for the benefit of the services provided by us or services provided by other third parties;
6. monitor and record calls and electronic communications with you for recording, quality, training, investigative and fraud prevention purposes; dan/atau
7. perform internal management to operate control and management information systems and perform internal audits or permit the conduct of external audits.