PRIVACY POLICY (INTEGRAL PART OF TERMS AND CONDITIONS)

Last modified on: 24 May 2023

PREAMBLE

  1. PT Motion Tech Indonesia, a company established under the laws of the Republic of Indonesia (we, our, or us) recognizes the importance of privacy and personal data and information to our insurance partners (you or your).
  2. This Privacy Policy is an integral part of our Terms & Conditions and applies to the use of our websites and mobile applications, including but not limited to www.mytokoto.com (Website) by you.
  3. By clicking the check box that appears alongside this Privacy Policy on our Website, you confirm that you have read, understood, and agreed to this Privacy Policy.
  4. You must not be a child (as defined by applicable laws and regulations) and must be of legal capacity in your country of residence to enter into a binding electronic legal agreement in order to accept this Privacy Policy.
  5. We understand that providing data and information online requires trust from you, and it is our priority to ensure the security and confidentiality of any personal or other data and information that you provide to us (Data). We only collect, record, use, disclose, manage, store, correct, and remove Data as long as it is necessary and relevant to provide our products and services, and in accordance with applicable laws and regulations.
  6. We use physical, technological, and administrative safeguards to preserve the security and confidentiality of Data and to prevent the damage, destruction, leakage,and misuse of Data. In the event that Data under our control is compromised as a result of a breach of security or confidentiality, we shall take reasonable steps to investigate the situation and where appropriate, notify persons whose Data may have been compromised and take other steps in accordance with applicable laws and regulations.
  7. We shall use our best efforts to protect Data; however, you acknowledge that:
    • the delivery of Data via the internet is not completely safe; and
    • we are unable toascertain the wholeness and accuracy of Data that you send through the internet or represent and warrant that such Data cannot not be accessed, disclosed, changed, destroyed, or intercepted by unauthorized third parties due to factors that are outside of our control. You are responsible for protecting the confidentiality of any Data that you provide to us including but not limited to your passwords, and for the safety of the device that you use.
  8. We do not collect, record, use, manage, store, or correct Data from children (as defined by applicable laws and regulations). If we learn that we have inadvertently collected, recorded, used, managed stored or corrected Data from a child (as defined by applicable laws and regulations), we shall remove such Data as soon as possible. If you believe that we may have Data from a child (as defined by applicable laws and regulations), please contact us immediately at the contact details listed below.
  9. We may amend this Privacy Policy at any time as necessary to comply with applicable laws and regulations or to reflect any changes to our operational or technological practices. We shall use reasonable endeavours to notify you of any material amendments to this Privacy Policy via emails or notices on our Website. You are encouraged to review this Privacy Policy periodically such that you are familiar with the latest version. If you do not agree with any amendments to this Privacy Policy, please do not continue using our Website. Otherwise, you shall be deemed to have consented to any amendments to this Privacy Policy.

DATA COLLECTION & RECORDING

  1. When you use our Website, we collect Data that is necessary and relevant to provide our products and services using lawful and fair methods, including but not limited to:
    • User Data, including but not limited to full names, addresses, email addresses, phone numbers, identification documents and biometric information (including but not limited to face recognition). User Data is collected when creating accounts on our Website;
    • Transaction Data, including but not limited to customer names, customer addresses, transaction prices, and transaction dates and times. Transaction Data is collected when purchasing products and services on our Website;
    • Financial Data, including but not limited to bank account and credit card details. Financial Data is collected when completing payments for products and services on our Website; and
    • Communication Data, including but not limited to messages sent to us via telephone, mail, email, or instant messaging apps.
  2. When you use our Website, we record Data that is necessary and relevant to provide our products and services using lawful and fair methods (in some cases using cookies, pixel tags, and similar technologies that create and maintain unique identifiers), including but not limited to:
    • Location Data, including but not limited to IP addresses, Wi-Fi locations, and geo-locations;
    • Activity Data, including but not limited to registrations, logins, and transactions;
    • Usage Data, including but not limited to interactions, saved choices, and selected settings; and
    • Device Data, including but not limited to device models, OS versions, serialnumbers, unique device identifiers, and mobile network details.
  3. We do not collect or record Data relating to your customers contact details.
  4. You hereby represent and warrant that all Data that you provide to us in connection with the use of our Website belongs to you. However, if you provide us with Data that belongs to other persons, then you represent and warrant that
    • you have informed and obtained the consent from such persons prior to providing the Data to us;
    • you have the authority to provide the Data to us on behalf of such persons; and
    • such persons have provided consent to allow us to use the Data in accordance with this Privacy Policy.

DATA USAGE

  1. We may use all or part of the Data collected and recorded from you for the following purposes without limitation:
    • Registering and identifying you as a user on our Website;
    • Providing you with access to your dashboard on our Website;
    • Providing you with the tools to purchase the products and services listed on our Website;
    • Improving and developing new products and services for our Website, including through analytics, testing, and research;
    • Analyzing your activities and behaviour in order to customize and improve your experience on our Website;
    • Engaging in internal activities to maintain our Website, such as fixing bugs and enhancing cybersecurity;
    • Communicating with you via telephone, mail, email, or instant messaging apps for any queries or complaints raised relating to our Website;
    • Informing you about the latest products and services on our Website, including any contests, events, promotions, surveys, and others similar matters;
    • Offering or providing products and services from any of our partners or service providers; and
    • Sending administrative information to you relating to our Website, including any changes to the Terms & Conditions or this Privacy Policy.
  2. We do not use Data for purposes other than those listed above without your explicit consent.
  3. We do not use Data to contact your customers directly.

DATA DISCLOSURE

  1. We do not disclose Data to third parties without your explicit consent.
  2. However, we may disclose Data as follows:
    • It is necessary and relevant to disclose Data to our Partner (as defined in the Terms & Conditions) in order for you to purchase general insurance policies underwritten by our Partner that are offered via our Website.
    • It is necessary and relevant to disclose Data to third parties that provide products and services to process your activities on our Website, including but not limited to financial services, marketing, and logistics firms. It is also necessary and relevant to disclose Data to analytics, testing, and research firms in order to continuously improve our products and services and develop new products and services.
    • We may disclose Data if we reasonably believe that such action is necessary to comply with applicable laws and regulations or to detect and investigate contractual breaches or illegal activities by you.

DATA MANAGEMENT & STORAGE

  1. We manage and store Data as long as it is required by applicable laws and regulations or as long as the Data is still necessary and relevant to provide our products and services.
  2. Please note that it is possible for Data to be managed and stored by third parties in certain ways that are inconsistent with this Privacy Policy. We do not permit or encourage the management or storage of Data in any way other than as specified in this Privacy Policy, and we are not responsible to you for any such act by third parties. You agree to indemnify, defend, and hold us, our officials, directors, employees, agents, partners, suppliers, contractors, and affiliates harmless from and against every and all losses, claims, obligations, fees, damages, and costs (including but not limited to legal fees and full indemnity expenses) generated directly or indirectly from the storage or management of Data by third parties

DATA CORRECTION

  1. You are responsible for ensuring the accuracy and completeness of Data prior to its submission to us. If you believe that any Data held by us contains errors or omissions, please log into your account on our Website and correct the Data as soon as reasonably practicable. If you wish to correct any errors or omissions in Data that cannot be corrected via your account on our Website, please submit your requests to our contact details listed below.
  2. We reserve the right to refuse your requests to correct some or all of the Data held by us. This includes but is not limited to situations in which Data may contain references to other persons or in which the requests to correct Data are for reasons we deem irrelevant or troublesome.

DATA REMOVAL

  1. You have the right to request us to remove some or all of the Data provided by you to us, to the extent permitted by applicable laws and regulations. You may submit removal requests to our contact details listed below. Please note that by requesting the removal of Data, we may no longer be able to provide you with some or all of our products and services and we shall not be liable to you for any losses or claims arising out of or in connection with such termination of your access to our products and services.
  2. We shall otherwise remove Data:
    • If we have completed the purposes for which the Data was collected or recorded; and
    • If we are no longer permitted or required by applicable laws and regulations to retain the Data,
    in any event, in accordance with applicable laws and regulations.

LINKS TO THIRD PARTY SITES

  1. Our Website may, from time to time, contain links to third party websites, including those of our partners and service providers. We are not responsible for any privacy policies on such third party websites. You are responsible for reading and understanding the respective privacy policies on such third party websites.
  2. Notwithstanding the above, please contact us at the contact details listed below us if you find that any links to third party websites on our Website that contain information and data that is unlawful. We shall, at our sole discretion, remove links to such third party websites from our Website.

COOKIES

  1. Cookies are small files that automatically appear on devices and perform the function of saving preferences and configurations while visiting websites, including our Website. Although your devices may automatically accept cookies, you may choose to make changes through your browser settings, namely by choosing to refuse cookies. Note that accepting cookies may also allow us to use features provided by third parties in order to improve our content, including customizing and serving advertisements to you based on interests or visit history.

YOUR CONSENT

  1. By clicking the check box that appears alongside this Privacy Policy on our Website, you confirm that you have read, understood, and agreed to this Privacy Policy and you accept all of its terms and conditions. In particular, you consent to us collecting, recording, using, disclosing, managing storing, correcting, and removing Data in accordance with this Privacy Policy.
  2. You may withdraw your consent to this Privacy Policy at any time by providing us written notification at the contact details listed below. Upon your request, we will cease to collect, record, use, disclose, manage, store, correct, and remove Data unless otherwise required by applicable laws and regulations. Note that by withdrawing your consent to this Privacy Policy, we may not no longer be able to provide you with some or all of our products and services and we will not be liable to you for any losses or claims arising out of or in connection with such termination of your access to our products and services.

CONTACT US

Should you have any queries or complaints in relation to this Privacy Policy, please contact us on: support@mytokoto.com