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MAPCLUB PRIVACY POLICY

MAPCLUB Privacy Policy (“Privacy Policy”) applies to your use of www.mapclub.com, its related websites and/or the MAPCLUB Application (collectively, the “Platform”). This Privacy Policy explains how We control and process Your Personal Information and is intended to respect and protect matters relating to the data and privacy of Users of the Platform and the MAPCLUB Customer Loyalty Program (collectively, “You/Your” or “User”). For purposes of this Privacy Policy, MAPCLUB acts as a Personal Data Controller to the extent that MAPCLUB determines the purposes of and exercises control over the processing of Your Personal Data.

This Privacy Policy, together with the terms of use of the Platform set out in the Terms and Conditions and other information displayed on the Platform, explains the types of information (including Personal Information) We collect, how We use such information, with whom We share such information, and the choices available to You in relation to Our collection, use and disclosure of such information. This Privacy Policy also explains the measures We take to protect and secure the information We obtain. The term “Personal Information” refers to information that can be used to identify a User.

By clicking “Daftar” or “Register”, or by logging in and/or registering using any other method available on the Login and/or Registration page of the Platform, You represent that all Personal Information You provide is true and valid. You acknowledge and understand this Privacy Policy and consent to Us obtaining, collecting, processing, analyzing, displaying, transmitting, disclosing, storing, modifying, deleting, managing and/or using such Personal Information for the purposes set out in this Privacy Policy.

1. Information We Collect

We collect Users’ Personal Information to provide services in accordance with their preferences, process purchase transactions, administer MAPCLUB Points, and for other purposes, provided that such purposes do not violate applicable laws and regulations in Indonesia. We may obtain Your Personal Information from various sources, including through the Platform, stores that cooperate with Us, email, telephone or social media when You contact or communicate with Us, events or promotions in which You participate, and through Our parent company, affiliates or subsidiaries, business partners and other third parties.

When You create an account or log in using another method available on the Platform, We may collect Personal Information including, but not limited to, Your name, address, telephone number, email address, date of birth, gender and other information We may require, including for identifying You. We may combine data obtained from these sources with other data We hold or with data held by other parties pursuant to a cooperation arrangement, in compliance with applicable laws and regulations.

We may also automatically collect certain information, such as cookies and web beacons, when You visit or use the Platform. A “Cookie” is a text file sent by a website to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or store information or settings in the browser. A “Web Beacon”, also known as an internet tag, pixel tag or clear GIF, is used to transmit information back to the Platform server. We may also use third-party website analytics tools that collect information about visitor traffic on the Platform.

We do not collect or store Your credit card details or personal banking details for payment processing or customer service purposes, including credit card expiry dates, CVV codes, SMS OTP codes or barcode applications, etc. (“Personal Banking Data”), without Your consent. However, MAPCLUB provides a feature for storing Personal Banking Data to facilitate transactions on the Platform. Such storage is carried out directly by PT Midtrans as an online payment service provider (payment gateway), which processes payments in accordance with its applicable terms and policies.

To protect Your Personal Banking Data relating to payments on MAPCLUB, MAPCLUB applies encrypted digital identification technology so that Your Personal Banking Data is not stored directly in MAPCLUB’s systems. Instead, such data is encrypted into a unique and secure substitute value that cannot be used to conduct transactions without Your valid authorization.

2. Use of Information We Collect

We may use information about You that We obtain for the following purposes:

  1. Registering Your MAPCLUB membership and managing and maintaining Your MAPCLUB account on the Platform.
  2. Providing the products or services You request.
  3. Processing, validating, confirming, verifying, dispatching and tracking Your account activities and transactions/purchases, including payment processing, delivery arrangements, returns/refunds and contacting You regarding Your orders.
  4. Recording Your purchase history on the Platform and/or at participating stores that cooperate with Us.
  5. Responding to Your questions and comments and providing appropriate customer support.
  6. Cooperating with affiliates or other parties that work with Us to provide services that We believe may be of interest or benefit to You.
  7. Informing You about Our products, services, offers, events and promotions, and offering products and services that We believe may be of interest to You, including contests, sweepstakes, prizes, advertising and relevant content.
  8. Managing Your participation in Our events, sweepstakes and other promotions.
  9. Contacting You to assist with and/or resolve transactions, purchase issues, use of the Platform and/or MAPCLUB Points, or to provide notifications concerning the protection of Your Personal Information.
  10. Enabling You to communicate with Us through blogs, social networks and other interactive media.
  11. Publishing Your testimonial about the Platform, including on Our websites, blogs and social networks. If We publish Your testimonial, We will only include Your first name, last initial, city and country.
  12. Customizing Our products and services according to Your personal interests when You use Our websites, applications and social media.
  13. Operating, evaluating and improving Our business and the products and services We offer.
  14. Analyzing and improving Our communications and marketing strategies, including determining whether emails sent to You have been received and read.
  15. Analyzing visitor trends and statistics relating to use of the Platform and Our social media, and purchases made by visitors, to improve the protection and security of Your Personal Information and Platform features.
  16. Preventing and protecting against fraud, unauthorized transactions, claims and other liabilities, and managing risks, including identifying hackers and other unauthorized users.
  17. Complying with orders to disclose Personal Information issued by authorized institutions for law-enforcement purposes or to satisfy applicable legal and regulatory requirements, including legal proceedings involving a User and MAPCLUB or suspected criminal acts such as fraud or data theft.
  18. Facilitating mergers, sales of corporate assets, consolidation or restructuring, financing or acquisitions involving MAPCLUB.
  19. Enforcing the Platform Terms and Conditions.
  20. Complying with applicable legal requirements, industry standards and Our applicable policies.
  21. Conducting risk and/or credit assessments and determining products to be offered to You, including financial services, credit products or other products, as applicable, provided by Us, Our affiliates or cooperating parties.
  22. Storing, maintaining and backing up Your Personal Data, whether for disaster recovery or other purposes, inside or outside Your jurisdiction.
  23. Any other purpose that We notify You in advance.

We may also use information collected through cookies and other automated devices to uniquely identify the electronic shopping cart You create on the Platform and enable You to retrieve a shopping cart You previously created. We may use cookies to identify and validate visitors.

We may combine the information we collect with publicly available information and information we receive from our parent company, affiliates, and subsidiaries, as well as business partners and other third parties.

We may use this combined information to enhance and personalize your membership and shopping experience with us, to inform you about our products, services, and events that may be of interest to you, as well as for other promotional and other purposes as we may deem necessary from time to time. We may also use information about you that we obtain by providing certain information during data collection.

3. Device Access

To enable You to make full use of the Platform, You may be asked to enable certain features on Your mobile phone, including access to contacts in Your address book, location, device/advertising identifiers, push notifications and browsing behavior.

You will be given the choice to allow or not allow Us to access Your mobile device. Such access helps Us facilitate Your use of the Platform, improve the User experience and provide functionality based on the access You grant. Certain features may not be available if You do not enable the relevant functions or permit access.

We will not collect and store information from Your mobile device. Access to mobile-device features is solely intended to improve the User experience. You may choose not to enable or permit such access and may disable or turn off the relevant permission at any time.

You agree and understand that We are not responsible for names, telephone numbers or other Personal Information in Your address book that You voluntarily share with Us. You will be responsible for requests, claims or damages from such third parties that may arise under applicable data protection laws or other regulations. You further agree that We are entitled to seek compensation from You for losses incurred by or affecting Us.

Without Your consent, We will not publish or disclose information We know or obtain from Your mobile device, unless We are legally required to do so under applicable laws and regulations in Indonesia, with prior notice to You.

4. Online Advertising

We may collect information about Your online activities to advertise products and services that correspond to Your personal interests. You may see advertisements on the Platform that direct You to pages on or outside the Platform.

You may also see advertisements for the Platform on other websites or applications because We participate in advertising networks. Advertising networks may target advertisements through demographic, behavioral and contextual methods and track online activities over time by automatically collecting information through cookies, web server logs, web beacons and other methods. This information may be used to display MAPCLUB and business-partner advertisements tailored to Your interests. Information collected may include visits to participating websites or mobile applications, pages or advertisements You viewed and activities You undertook. This process also helps Us measure marketing effectiveness.

5. The Information We Share

We do not sell or disclose Your Personal Information except as set out in this Privacy Policy. We may share the Personal Information We collect:

  1. with Our parent company, affiliates and subsidiaries for management, analysis and operational purposes;
  2. with business partners, including trademark owners/principals, third-party service providers, network providers and their participants, and other third parties where disclosure is necessary for business, professional or technical support;
  3. with payment service providers, banks and financial institutions for payment processing and authorization, fraud protection, credit-risk mitigation and customer support;
  4. with third-party partners so that they may inform You about offers, promotions and services;
  5. with advertising networks, social networks and data analytics providers;
  6. with third parties for joint promotional purposes, who are responsible for their own compliance with applicable privacy laws and regulations;
  7. with service providers for websites, mobile applications, service evaluation and optimization;
  8. with law-enforcement officials, government agencies, regulatory organizations, courts or other public authorities to comply with law, respond to government requests, enforce Our policies, or protect Our rights, property or safety or those of others;
  9. with other parties with Your consent or on another lawful basis permitted by applicable law.

Disclosure of Personal Information is limited to what is necessary for the relevant processing needs and purposes. Parties processing Personal Information on Our behalf must act on Our instructions, maintain confidentiality, implement adequate security measures, assist in fulfilling Your rights, and delete or return Personal Information after the services end in accordance with the contract and applicable law.

We may provide Your information to affiliates, business partners and/or service providers in countries outside Indonesia. Where information is transferred outside Indonesia, We will ensure that it is adequately protected. We will ensure that the destination country provides a level of personal data protection equivalent to or higher than Indonesia, or that the receiving third party has adequate and binding personal data protection standards.

6. Your Choices and Rights

In accordance with applicable laws and regulations, You have choices and rights in relation to Our processing of Your Personal Information. These rights may be exercised through the contact channel set out in the “Contact MAPCLUB” section of this Privacy Policy.

Your rights include:

  1. Right to Complete, Update and/or Correct Personal Information
    You may request that We complete, update and/or correct Personal Data that is incomplete, inaccurate or inconsistent with the actual circumstances.
  2. Right to Access and Obtain a Copy of Personal Information
    You may access Personal Data under Our control and obtain a copy in accordance with applicable laws and regulations.
  3. Right to Terminate Processing, Delete and/or Destroy Personal Information
    You may request that We terminate processing, delete and/or destroy Your Personal Data to the extent permitted by applicable laws and regulations.
    We may refuse or not fully comply where the information is required to fulfill legal obligations, resolve disputes, exercise or defend legal rights and claims, prevent fraud, maintain security or for other legitimate reasons permitted by law.
  4. Right to Withdraw Consent
    Where processing is based on consent, You may withdraw that consent. Withdrawal does not affect the lawfulness of processing carried out before withdrawal or stop processing based on another lawful ground.
    In certain circumstances, withdrawal may result in Your inability to use certain features, offers or access to the Platform.
  5. Right to Object to Decision-Making Based on Automated Processing
    You may object to a decision based solely on automated processing where it has legal effects or significant effects on You.
  6. Right to Suspend or Restrict Processing of Personal Information
    You may request suspension or restriction of processing in accordance with the processing purposes and applicable laws and regulations.
  7. Right to Use and Transfer Personal Information to Another Electronic System
    You may obtain Your Personal Information in a commonly used format readable by another electronic system and use or transfer it to another electronic system, provided that the systems can communicate securely and in accordance with applicable laws and regulations.

    We may refuse or not fully comply with the requests above for legitimate reasons or to satisfy requirements permitted under applicable laws and regulations.
7. Retention Period of Users’ Personal Information

We retain Your Personal Information only for as long as necessary to fulfill the processing purposes described in this Privacy Policy, including providing and improving Platform services, performing contractual obligations, maintaining Platform security, preventing and handling fraud, resolving disputes and complying with applicable legal and regulatory obligations.

The retention period is determined by considering the processing purpose, type and sensitivity of the Personal Information, risks arising from processing, the duration of Our relationship with You, the need to establish, exercise or defend legal rights and claims, and retention obligations under applicable laws and regulations.

After the processing purpose has been fulfilled or the retention period has expired, We will delete, destroy and/or anonymize Users’ Personal Information so that it can no longer be used to identify the User, unless a lawful basis permits or requires Us to retain it for a longer period.

8. Links to Other Websites

The Platform may contain links to other pages or websites for Your convenience and information. Some may be operated by companies not affiliated with Us and may have their own Privacy Policies, which You should review. We are not responsible for the content, use or privacy practices of websites not affiliated with Us.

9. How We Protect Personal Information

We use administrative, technical and physical safeguards designed to help protect Personal Information from damage, loss, alteration, accidental or unlawful access, disclosure or use. For example, We use Secure Sockets Layer encryption to protect transaction information. No electronic transmission of information is completely secure, and We cannot guarantee that Our security measures will never be compromised or fail or will always be adequate and effective.

For additional protection, You should protect Your MAPCLUB username, account password and Personal Banking Data and not share such information with anyone. You should log out and close the browser when finished using the Platform. We will never request Your MAPCLUB username and password through any method. We will also never request Your Personal Banking Data, except data that needs to be provided when making a payment on MAPCLUB.

We are not responsible for unauthorized use by third parties resulting from circumstances beyond Our control. Transactions resulting from Your negligence that causes Your Personal Information or Personal Banking Data to become known to another third party are entirely Your responsibility.

Users’ Personal Information may be stored or processed outside the User’s country by persons working for MAPCLUB or by third-party service providers, vendors, suppliers, partners, contractors or affiliates. In such circumstances, MAPCLUB will ensure that the Personal Information remains protected in accordance with this Privacy Policy..

10. Age Restriction

If You are under 17 years of age, You must obtain the consent of and involve a parent or lawful guardian before registering as a MAPCLUB Member, providing Personal Data, using Platform features or purchasing products on the Platform. If You do not obtain such consent or involvement, You must stop using the Platform.

11. Changes to the Privacy Policy

This Privacy Policy may be amended and updated periodically. We will publish a notice on the Platform if there are significant changes and will state when the changes were last made.

We recommend that You review this Privacy Policy from time to time. By continuing to access and use the Platform, Users will be deemed to have agreed to changes made to this Privacy Policy.

12. Acceptance of and Opting Out of Promotional Emails

When You register to receive promotional emails, You may opt out of Our regular updates, including:

  1. Email notifications regarding new products, features, improvements, special offers, contests, events and special shopping promotions.
  2. Direct-mail notifications regarding new products, features, improvements, special offers, contests, events and special shopping promotions.

You may stop receiving the service or updates at any time without additional charges. Every email We send contains an automatic unsubscribe link.

13. Account Deletion Requests

You may request deletion of Your Account, including Personal Data such as Your name, address, email address and telephone number, as well as Your transactions and MAPCLUB membership.

Deleting Your Account will permanently delete all data associated with the Account, transactions and MAPCLUB membership, and such data cannot be restored. The deleted data includes:

  1. Personal data;
  2. Reward Points;
  3. Store credit balance; and
  4. Transaction history

Notes:

  1. You may create a new account using the same data. However, transaction history, Reward Points and store credit balance from the previous account cannot be restored to the new account.
  2. MAPCLUB will only retain records from a deleted account for sales calculations, product availability, financial audit purposes, and retention obligations under applicable laws and regulations.
14. Contact MAPCLUB

If You have any questions, comments, complaints or claims regarding this Privacy Policy, or wish to exercise Your choices and rights in relation to the processing of Your Personal Information by Us, please contact MAPCLUB at hello@mapclub.com.