1. Personal information which we collect

The following Privacy Policy describes how we, Kecilin (Affiliates, “we”, “us” or “our”) collect, store, use, process, retain, transfer, disclose and protect your personal information. This Privacy Policy applies to all users of our applications, website (h ttps://kecilin.id/), services, or products, unless covered by a separate privacy policy. Please read this Privacy Policy thoroughly to ensure that you understand our data processing practices.

a. Information you submit

Registration information you submit and the information collected based on industry practice and demand of products and services. At the time you register your Kecilin account, in order to identify the user and facilitate contact, you shall provide the real and effective information. You understand and agree that under necessary circumstances (e.g. cancel of account, etc.), we may identify you based on your registration information, so as to prevent any other person from using your identity to operate fraudulently which will affect your normal use of Our products and services. Registration information you submit may include your name, email address and phone number. In addition, we may collect the information from communication if you contact us directly, such as for customer support, we may receive additional information about you, including the content, date and time of your message and our reply.

b. 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 or who perform functions on our behalf) such as the details of payment you make for our products and/or services using a partner’s payment solution. In such cases, we will only collect your personal information for or in connection with the purposes for which such third parties are engaged, provided that we have taken reasonable steps to ensure that such third parties would undertake to us to obtain your consent for the disclosure of your personal information to us in line with this Privacy Policy and the applicable law.

c. Data information you upload

The information you may upload image, video, and document during using our services can be your personal information or the personal information of others protected by laws and may related to your or other’s private information protected by law that may involve your or other’s privacy, or is granted protection under copyright law, etc. You shall guarantee that you have obtained the necessary authorization to copy and upload such data information. You will be required to make proper setting and adopt appropriate security measure so as to prevent the leakage of data and damage to right owner’s interests. Please pay great attention to protecting your own or other’s data information. You shall refrain from disclosing the data information to the public without authorization.

d. The information we obtain during your use of Our products and services

Depending on which mobile device operating system you use, we may collect the following information:

Device Information. We receive information about your device, including IP address, device identifiers, advertising identifiers, publisher identifiers, web browser type, operating system version, device manufacturer & model, your Internet Service Provider (ISP), power consumption, and carrier or network.

Kecilin Application Usage Information. We receive information about your interactions with the Kecilin application, like the pages or other content you view, the dates and times of your interactions, the frequency of your usage sessions.

T hird Party App and Website Usage. When you install the Kecilin application, we may receive the names of the applications installed on your device and your interactions with those applications, network traffic, in-app purchases, the dates and times of your interactions, and the frequency of your usage sessions. We receive similar information about your interactions with websites that you access on your mobile device.

Plan information. Text message & phone call information (e.g. the number of text messages sent/received by the user) is collected and stored locally on your device and never transmitted. We do not collect or read the contents of such messages. Text message & phone call information is only used to allow you to see and understand your plan usage. Additionally, we receive information about your mobile plan and data used.

Location Information. With your consent, we may obtain information about your physical location at regular intervals when you use our products and services, such as by use of geolocation features in the device(s) through which you access the Kecilin application and webistes. In addition, we may infer your location from other information we collect (for example, your IP address indicates the general geographic region from which you are connecting to the internet). We may use location information to provide you with features, notifications, or other content that is influenced by your location.

2. Purpose of Information Collection

We provide services to you by means of website, software and other applications. We collect your information only for the purpose of providing products and services to you (functions designed for each product differs from one another; you should familiarize yourselves with these differences and make your own privacy settings based on your needs and the circumstance), improving your experience of using Our products and services, facilitating your use of Our products and services more expediently, obtaining the information that you need in a faster and more accurate way, and conducting the commercial exploration of big data application, on condition of ensuring legal compliance and protection of privacy.

3. How Kecilin Discloses Your Information

We will share your information with the following selected third parties:

Our business partners so that we can make you special offers via our application(s);
Advertisers and advertising networks that require the data to select and serve adverts to you and others;
Cloud storage providers to store the information you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;
Analytics and search engine providers that assist us in the optimization and improvement of our products and services;
IT service providers;
Our data center and the servers of our host providers; and
Other third parties whom you have consented to.

We will also share your information with any member, subsidiary, parent, or affiliate of our corporate group, only for the purposes set out above, to assist in the improvement and optimization of our products and services, in order to prevent illegal uses, increase user numbers, development, engineering and analysis of information or for our internal business purposes.

We will share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if such use is reasonably necessary to:

Comply with legal obligation, process or request;
Enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
Detect, prevent or otherwise address security, fraud or technical issues; or
Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

We will also disclose your information to third parties:

In connection with or during negotiations of any merger, sale or buy any business or /assets, consolidation or restructuring, financing or acquisitions of all or a portion of our business by or into another company, in which case we will disclose your data to the prospective seller or buyer of such business or /assets or financier; or
If we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our /assets. In such transactions, user information will be among the transferred /assets.

4. The Use of Personal Information Which We Collect

By using Our products and services, you consent to and grant authorization to our collection, processing and disclosing of your information, including the device and software user information, personal information and content information uploaded by user (mainly the image information you uploaded; regarding the uploaded content, you warrant that you have the intellectual property involved therein or have obtained the relevant license and there is no infringement of third party’s right). The information is only used for the optimization of software interface interaction. No specific information will be used or disclosed.

You understand and agree that the information you make public (because of your own choice or our default setting, e.g. the document or user name you share) may be browsed, reposted and commented by other users of our services. You may protect your critical information by deciding whether to upload certain information, and whether to turn on the specific function of Our products and services. We generally use the information we collect:

To identify you, and to administer, manage or verify your account;
To fulfill requests for products, services, platform functionality, support and information for internal
Operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback;
To process and respond to enquiries and feedback received from you;
To improve and develop our products and services and conduct product development;
To send promotional materials from us or on behalf of our affiliates and trusted third parties;
To measure and understand the effectiveness of the advertising we serve to you and others and to deliver targeted advertising;
To understand how you use the products and services, including across your devices;
To help us detect abuse, fraud, and illegal activity on the platform;
To ensure that you are old enough to use the products and services (as required by law);
To communicate with you, including to notify you about changes in our services;
To to enforce our terms, conditions, and policies;
To inform our algorithms;
To combine all the information we collect or receive about you for any of the foregoing purposes;
For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

5. Files Uploaded

All files uploaded in this service are automatically deleted after a few hours. Also all the files that have been converted or processed by our service are automatically deleted after a few hours. Please do not ask us to recover a file you have uploaded or converted with our web service, we can't do that because all the files uploaded and processes by our service are automatically deleted. We have no way to recover or restore them from our web server after they have been successfully deleted. You acknowledge and agree that our system administrators might access or analyze the files for security reasons, and that in some cases the automatic deletion of the files may fail.

6. Retention of Personal Information

We use the following criteria to determine the period for which we will keep your information:

Our contractual obligations and rights in relation to the information involved;
Legal obligation(s) under applicable law(s) and regulations to retain data for a certain period of time;
Statute of limitations under applicable law(s);
Our legitimate business purposes; and
Disputes or potential disputes.

After you have terminated your use of our products and services, we can store your information in an aggregated and anonymised format. Notwithstanding the foregoing, we can also retain any personal information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.

Upon our deletion of your personal information, some of your personal information might be retained by the other party whom we, upon on your consent, or otherwise you directly have disclosed. To the fullest extent permitted by the applicable law, 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, 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 unauthorized retention of your personal information by third party.

7. Security of Your Personal Information

Confidentiality of your personal information is of utmost importance to us. We will use all reasonable efforts to protect and secure your personal information against access, collection, use or disclosure by unauthorized persons and against unlawful processing, accidental loss, destruction and damage or similar risks. Unfortunately, the transmission of information via 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 for keeping your account details confidential and you must not share your account details. In addition, you must always maintain the security of the mobile device that you use.

8. Anonymous Data

We may create, use, license or disclose personal information, provided, however, (i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, and (ii) that has been combined with similar data such that the original data forms a part of a larger data set.

9. Changes

We will generally notify all users of any material changes to this Privacy Policy, through a notice on our platform. However, you should look at this Privacy Policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of our products and services after the date of the updated policy constitutes your acceptance of the updated Privacy Policy. The changes may affect not only personal information we collect in the future, but also the personal information we have collected prior the date of the Privacy Policy change. If you do not agree to the updated Privacy Policy, you must stop accessing or using our products and services.

10. Language

If there is any inconsistency between the English version of this Privacy Policy and the Bahasa Indonesia version, the Bahasa Indonesia version shall prevail.

11. Third-Party Platforms

a. Our platform, 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 consult the terms and conditions and privacy policies of those third-party websites to find out how they collect and use your Personal Information.
b. Advertisements contained on our platform, 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.

12. Contact

If you have any questions regarding this Privacy Policy or you would like to obtain access and/or make corrections to your Personal Information, please contact ….

Privacy Policy as of 21 January 2020