Privacy policy

1. Introduction

This Privacy Policy or Privacy Notice ("Privacy Notice") is effective starting Monday, February 19, 2024.

This Privacy Notice explains how we, PT Global Sukses Digital (hereinafter referred to as "DOSS" or "we"), collect, store, control, use, process, analyze, correct, update, display, announce, transfer, disclose, and protect your Personal Data ("Processing Personal Data" or "Personal Data Processing"). This Privacy Notice applies to all users of our mobile application (including apps), website (including www.doss.co.id), features, services, and products (collectively referred to as "Application").

Please read this Privacy Notice thoroughly to ensure that you understand our data protection practices.

1.1 "Personal Data" refers to information related to data that can or may potentially be accessed by an organization.

1.2 By using the Service, registering an account with us, visiting our Platform, or accessing our Services, you acknowledge and agree that you accept the practices, terms, and/or policies outlined in this Privacy Policy, and you hereby permit us to collect, use, disclose, and/or process your personal data as described herein. If we make changes to our Privacy Policy, we will post the changes or the updated Privacy Policy on our Platform without providing written notice. We reserve the right to amend this Privacy Policy at any time.

1.3 This Policy applies in relation to other notices, consent clauses applicable to the collection, storage, use, disclosure, and/or processing of your personal data by us, and is not intended to override such notices or clauses unless we specify otherwise.

1.4 This policy applies to all users of the DOSS application and website who use the Services unless expressly stated otherwise.

2. Data Collected Every Time You Use the Application

2.1 We will/may collect your personal data:

· When you register and/or use our Services or Platform, or open an account with us.

· When you fill in information while using our Services or Platform, submit any form, including, but not limited to, other forms related to our products and services, electronically;

· When you use our products and services;

· When you interact with us, such as through phone calls, emails, face-to-face meetings, social media platforms, and chat applications like WhatsApp, including when you interact with our customer service agents;

· When you use our electronic services, or interact with us through our apps or use services on our Platform. This includes, but is not limited to, cookies we may use when interacting with our app or website;

· When you conduct transactions via our Services;

· When you submit your personal data to us for any reason.

The list above is not intended to be exhaustive and merely sets out a few common examples of when your personal data may be collected.

2.2 We may collect your personal data from you, our affiliates, third parties, and other sources, including but not limited to business partners (such as logistics or payment service providers), credit bureaus or assessment agencies, marketing service providers or partners, referral or loyalty programs, other users of our Services, or data that is publicly available or sourced from the government.

2.3 In certain circumstances, you may provide personal data of others to us (such as your family members or friends or people in your contact list). If you provide us with their personal data, you represent and warrant that you have obtained consent for their personal data to be processed in connection with this Policy.

3. Personal Data Collected

3.1 Personal data that may be collected by DOSS includes but is not limited to:

· Name;

· Email address;

· Date of birth;

· Billing address;

· Bank account and payment information;

· Phone number;

· Gender;

· Information sent by or related to the device(s) used to access our Services or Platform;

· Information about your network, including your contact list when you grant consent on your device, and people and accounts interacting with you;

· Photos, including photos taken for electronic delivery proof purposes, or audio or video recordings;

· Government-issued identification or other information required for our due diligence, customer identification, verification of identity, and/or fraud prevention purposes;

· Other information about the User when the User registers to use our Services or Platform, and when the User uses the Services or Platform, as well as information related to how the User uses our Services or Platform;

· Information or data related to any third party or individual not registered on the Platform, provided by the User when using the Services;

· All data about the content used by the User.

3.2 By agreeing to this Privacy Policy, you agree not to provide us with any inaccurate or misleading information, and you agree to notify us of any inaccuracies or changes to such information. We reserve the right at our discretion to require further documentation to verify the information you have provided.

4. Use of the Information Provided

4.1 We may collect, use, disclose, and/or process your personal data for one or more of the following purposes:

· To consider and/or process your application/transaction with us or your transaction and communication with third parties through the Service;

· To manage, operate, provide and/or handle your use and/or access to our Services and Platform (including, but not limited to, remembering your preferences), as well as your relationship and user account with us;

· To respond to, process, deal with, or resolve transactions, complaints, and/or fulfill your requests for certain products and services, and notify you about service issues and unusual account actions;

· To protect personal safety and the rights, property, or safety of others;

· For identification, verification, due diligence, or customer knowledge purposes;

· To make product recommendations;

· To maintain and provide software updates and/or other updates, as well as support that may be required from time to time to ensure the smooth operation of our Services;

· To deal with or facilitate customer service, follow your instructions, handle or respond to any questions you (or purportedly) raised, or on your behalf;

· To contact or communicate with you via phone calls, text messages, faxes, emails, and/or mail or other means for the purpose of managing and/or managing your relationship with us or your use of our Services, such as but not limited to, communicating administrative information about our Services to you. You acknowledge and agree that such communications by us may be carried out by sending letters, documents, or notices to you, which may involve disclosing certain personal data about you to carry out the delivery, and may also appear on the outer cover of envelopes/packages;

· To enable other Users to interact, connect with you, or view some of your activities on the Platform, including notifying you when other Users have sent you personal messages, posted comments for you on the Platform, or connected with you using social features on the Platform;

· To conduct research, analysis, and development activities (including, but not limited to, data analysis, surveys, product and service development and/or profiling) to analyze how you use our Services, improve our Services or products, and/or enhance your customer experience;

· For marketing and advertising, and in this regard, to send you, through various communication channels, marketing and promotional information and materials related to products and/or services, whether existing products or services or created in the future;

· To respond to legal processes or comply with or as required by any applicable law, government requirements, or regulations under the relevant jurisdiction or if we have a good faith belief that disclosure is necessary, including, but not limited to, fulfilling disclosure requirements based on legal obligations binding on DOSS or its affiliates (including, where applicable, displaying your name, contact details, and company details);

· To generate statistics and research for internal reporting and as required by law and/or record-keeping requirements;

· To conduct due diligence or other screening activities (including, but not limited to, background checks) as required by legal obligations or regulations or risk management procedures that may be required by law or imposed by us;

· To store, maintain, back up (whether for disaster recovery or other purposes) your personal data, both within and outside your jurisdiction;

· For any other purpose that we will notify you about at the time we obtain your consent. (collectively referred to as the “Purposes”).

4.2 You acknowledge, agree, and consent that DOSS may access, store, and disclose your personal data and Account Content if required by law or in accordance with court orders or by the priority of government or regulators having jurisdiction over DOSS or with a good faith belief that such storage or disclosure is reasonably necessary to: (a) comply with legal processes; (b) meet requests from any government authority or regulator having jurisdiction over DOSS; (c) enforce DOSS’s Terms of Service or this Privacy Policy; (d) respond to any claims or threats of claims against DOSS or claims that Content violates third-party rights; (e) respond to your requests for customer service; or (f) protect DOSS’s rights, property, or personal safety, its users, and/or the public.

4.3 Since the purposes for which we may collect, use, disclose, or process your personal data depend on the situation at hand, such purposes may not be listed above. However, we will notify you of such other purposes at the time we obtain your consent unless data processing without your consent is permitted under Privacy Laws.

5. Process for Withdrawal of User Information

5.1 Regarding the implementation of personal data protection on our systems. User’s personal data is behind a secure network that can only be accessed by a limited number of employees with special access rights to the system. However, there is no guarantee or absolute security that is unavoidable.

5.2 We will store personal data in accordance with Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we reasonably believe that (i) the purpose for which the personal data was collected is no longer served by its storage; (ii) storage is no longer required for any legal or business purpose; and (iii) there is no valid court order justifying further retention of the personal data. If you stop using our Platform, or your permission to use thePlatform and/or Services is terminated or withdrawn, we may continue to store, use, and/or disclose your personal data in accordance with this Privacy Policy and our obligations under Privacy Laws and other applicable laws. Subject to applicable laws, we may securely dispose of your personal data without prior notice to you.

6. Disclosure of Information Collected to External Parties

6.1 In conducting our business, we may need to use, process, disclose, and/or transfer your personal data to third-party service providers, agents, and/or our affiliates or related companies, and/or other third parties, which may be located in Indonesia or outside Indonesia, for one or more of the Purposes mentioned above. Third-party service providers, agents, and/or affiliates or related companies and/or other third parties will process your personal data on our behalf or for others, for one or more of the Purposes mentioned above. We strive to ensure that third parties and our affiliates maintain the security of your personal data from unauthorized access, collection, use, disclosure, processing, or similar risks and store your personal data only as long as it is required for the Purposes mentioned above. Third parties may include, but are not limited to:

· Our subsidiaries, affiliates, and related companies;

· Agents, service providers, and other third parties we use to support our business and/or whose products and/or services are available or provided on the Platform. This includes but is not limited to parties providing administrative or other services and/or products to us and/or to users such as postal services, logistics providers, financial services providers, credit rating companies, telecommunications companies, IT companies, and data centers;

· Government authorities or regulators with jurisdiction over DOSS;

· Third parties to whom we disclose data for one or more Purposes, and such third parties will, in turn, collect and process your personal data for one or more Purposes.

7. Process for Withdrawing Consent or Correcting the Information You Have Provided Us

7.1 You may withdraw your consent for the collection, use, and/or disclosure and/or request the deletion of your personal data we hold or control, by emailing the Personal Data Protection Officer at admin@doss.co.id, and we will process your request in accordance with this Privacy Policy and our obligations under Privacy Laws and other applicable laws. However, withdrawing your consent may mean that we will not be able to continue providing the Services to you, and we may have to terminate our relationship with you and/or the contract you made with us.

7.2 Request for Personal Data Correction

7.2.1 If you have an account with us, you can access and/or correct your personal data that we currently hold or control through the Account Settings page on the Platform. If you do not have an account with us, you may request to access and/or correct your personal data that we currently hold or control by submitting a written request to us. We will need sufficient information from you to verify your identity and the nature of your request so that we can process it. Therefore, please submit your request in writing by emailing admin@doss.co.id.

7.2.2 We will correct/update your personal data based on your request in accordance with the provisions in Privacy Laws, unless otherwise specified by other applicable regulations.