Privacy Policy

In order to ensure that the data relating to identity, contact, profile, behavior on the Platform and the data relating to Your other personal information which identifiable both directly or indirectly (“Personal Data”) is always protected when You access the Platformand/or use the features contained therein which developed by PT Spektrum Cahaya Nebula (“Socialights” or “We” or “Our” or “Us”), We are committed to protect the Personal Data that is furtherly set forth under this Privacy Policy.

This Privacy Policy (“Policy”) constitutes a set of rules that are integral parts of the Terms and Conditions, which are made as the basis of Our activities in obtainment and collection, processing, storing, displaying, distribution and removal of Personal Data on the Platform. The terms and definitions started in capital letters contained under the page of the Terms and Conditions shall have the same meaning and interpretation as the terms used in this Policy, unless otherwise specified under this Policy.

By accessing and/or using the Platform, You have read, understood, and given approval to Platform Provider to obtain, collect, store, process, and use Personal Data as set forth under this Policy and are bound to all the terms set forth in this Policy. If You do not approve this Policy, You will not be granted the permission to access and/or use the Platform.

Subject to this Policy, You are also considered to be bound by the Terms and Conditions whereas this Policy constitutes an inseparable and integral part of the Terms and Conditions. The invalidity of the Terms and Conditions of the Platform Usage shall not cause this Policy to become illegal, invalid, and/or unenforceable.

1. Acquisition or Collection of Personal Data

When You access the Platform or use the Features contained on the Platform, You are directly or indirectly provide Us with Personal Data. For example, when You register by creating an Account in the Platform, We shall collect and store Your Personal Data in the form of Your name, email address, password, and other data needed so You can have access to Your Account. In addition, We collect Your Personal Data including when You:

accessing the Platform and/ or using the Features;
registering by creating an Account on the Platform;
responding the surveys distributed by Us;
sending reviews, messages, critics and/ or Your suggestions to Us;
contact Us, through the communication facilities that We provide;
use the Features that require access permission on Your device; or
entering information(s) in relation with Personal Data in any form to the Platform and/ or Feature.

The Personal Data that We collect is the data that You have provided to Us in the manner that We have previously explained. The Personal Data shall include, among others:

data relating to Your personal information, including Your name, address, telephone number, e-mail address, Identification Card (Kartu Tanda Penduduk), and/ or the photo of You;
Your response to the survey We provided;
review and rating which given to the Product and/ or Services;
data of real or approximate location such as Internet Protocol addresses, Wi-Fi locations, geo-locations, and others;
data in the form of time of each usage activity, including registration, login, transaction, and others;
Your data of usage and/ or preferences, including Your interactions in using the Platform, stored choices, Activity that You choose or trade as well as the settings selected in the Platform;
information about the software and hardware that You use to access the Platform and/ or use the Feature;
data log, including records on the server that received a data such as the IP address of the device, the date and time of access, feature Platform or page viewed, site work processes and other system activities;
i.interactions, reviews, critics, suggestions and/ or messages from You which addressed to Us, including everything that is disclosed when You contact Us through the means of communication that We provide or when We provide the assistance to resolve the issues that arise in connection with the use of the Platform; and/ or
j.other things that You do in the Platform and/ or Feature and other data that You provide into the Platform and/ or Feature.

You hereby represent and warrant that the Personal Data which You input onto the Platform and/ or Features is Your Personal Data based on the actual condition, and You are fully responsible for the Personal Data and You have full authority and/ or personal rights to submit Personal Data to Us, including releasing Us from any civil lawsuits or criminal charges arising from misleading information relating to Personal Data that You input into the Platform and/ or Features.
We have the right from time to time to request the authentication, verification and/ or updating of Your Personal Data, therefore Your data and information is accurate, complete and up-to-date, including temporarily/permanently terminating or prohibit You to access certain Features optimally in the event that You have not conducted authentication and update Your Personal Data.
By continuing to access the Platform, using Features, and/ or other Our services, You hereby expressly giving approval to Us to obtain and collect Your Personal Data as set out in Article 1.1 and 1.2 in this Policy, and hereby represents that such approval is made without any coercion, with full capacity, and consciously.

2. Use of Personal Data

The Personal Data that We have collected and obtained shall be fully used for Your and Our interests in accordance with this Policy and the Applicable Law in Indonesia. We may use the Personal Data for, among others:

process Your data for Your needs in accessing Platform, using Features;
contacting You in regards of the matters relating to Your usage and / or access of the Platform and Features available on the Platform;
personalizing and/ or making adjustments according to Your preferences based on your Personal Data for the purpose of adjusting and maximizing your experience while using the Platform;
communicating with You in connection with the requests for critics and suggestions;
inform the information, insight, surveys or interesting program(s) or promotion for You;
Platform and/ or Feature development in order to improve Our services, including using information obtained for research, analyzing, product development and testing purposes to improve Your security and comfort in accessing and using the Platform and/ or Feature, and developing Features and/ or new product;
business development, service or marketing strategy;
measure and improve Your experience and satisfaction toward the Platform;
assist You when filing a report to Us regarding the use of the Platform through the communication facilities We provide;
conduct monitoring or investigation of suspicious transactions or indicated transactions which containing materials of fraud or violations of the Terms and Conditions of the Platform Usage, or Applicable Law, as well as taking necessary actions as response on the outcome of such monitoring or investigation;
enforce and applying the Terms and Conditions of the Platform and/ or Big Platform Provider Terms and Conditions;
resolve complaints that We receive as well as solving problems in connection with the Platform and/ or Features in it; and/ or
for other purposes as notified to You at the time of Personal Data collection or other purposes as far as it is conducted in accordance with the Applicable Law.

You hereby understand that using Features in the Platform requires a process of authenticating, verifying, and/ or updating Your Personal Data. By continuing to access the Platform, using Features, and/ or other Our services, You hereby expressly give Your approval to the use, utilization and/ or disclosure of Your Personal Data, and hereby state that such approval is made without any coercion, with full capacity, and consciously.

3. Distribution of Personal Data to the Third Parties

We understand the confidentiality of Your Personal Data and We are committed not to sell, rent, display, or distribute Your Personal Data without Your prior consent unless otherwise specified in this Policy. We shall only disclose Your Personal Data to the third parties upon Your consent.
By continuing to access the Platform and use the Features and Our other services, You hereby grant Us the approval in any form to disclose Your Personal Data and You allow Us to provide access, disclose, and send the Personal Data to the other users on the Platform and the appointed third party to help Us provide the services for You (“Appointed Third Parties”), and hold Us harmless from any loss and damage resulted from the Appointed Third Parties failure to secure Your Personal Data. You fully acknowledge that this approval is made without any coercion, with full capacity, and consciously.
We are not able to guarantee the security of Your Personal Data on any third party systems including the Appointed Third Parties systems and We have no control or responsibility for the privacy policies or content of the third parties. Therefore, We recommend You to learn and examine the privacy policies of each third party, so that You understand their terms on handling Your Personal Data.
We are authorized to disclose Your Personal Data to comply with a valid court orders or decisions of legitimate government institutions or the provisions of Applicable Law. If possible and permitted, We shall send You a notification in the event that We are disclosing Your Personal Data.
You acknowledge and agree that in order to develop the Platform, We may use or share Your data and information which do not identify You as an individual, to be processed, developed, and cooperated with Appointed Third Parties or other third party. We acknowledge Your privacy, therefore the data and information that We may use and share are aggregate data which do not identify You as an individual.

4. Use of Cookies and Third Party Services

Cookies are text files that are placed on Your computer for recording purposes. We use cookies to help Us improve Your comfort in accessing Our Platform.
Cookies shall record Your Personal Data as well as the data that You input into the Platform. For example, if You create an account in the Platform, cookies shall help Us recall specific Personal Data for Your next visit. When You re-access the Platform, the Personal Data that You provided previously will be displayed, so the activation of cookies shall facilitate You in accessing the Platform.
You may set to disable cookies in Your browser partially or entirely, but when You choose to disable cookies entirely (including significant cookies), You may not be able to access all of part the Platform and/or Features.
In general, the browser has a feature to control most cookies. To find out more about cookies, including but not limited to managing, deleting and seeing which cookies are active, You are encouraged to visit www.aboutcookies.org or www.allaboutcookies.org.
We reserve the right to use third party services to analyze Personal Data for Us, such as Google Analytics and other third party services that aim to develop Platform and Features, among others, Features that support communication services which provide facilities for Users to interact directly with Vendors. These third-party services including among others the collection of data from Your visits and activities while accessing the Platform and using the Feature.

5. Your Options and Transparency

In using the Platform and the Features that We provide, We respect You by providing options that include but are not limited to:

You are able to modify Your profile information through the Feature in the Platform, if You are registered as a User;
You are able to unsubscribe from the notification of a new offer, variety of the latest promo information, and exclusive offers if You no longer wish for such information;
You are able to deactivate Your Account through the setting feature that We provide on the Platform and reactivate the Account anytime, provided that remain subject to the procedure determined by Us from time to time. Please be informed that by deactivating the Account, all unused Coins will be deemed expired and cannot be used;
Your request to withdraw Your consent to the acquisition, use, or disclosure of your Personal Data by giving notice to Us through the Contact Us and You understand that the withdrawal request may result in Your access to the Platform being limited/ no longer able to access the Platform.

6. Storage and Removal

Your Personal Data that You input into the Platform as well as We obtain based on the provisions of Article 1 of this Policy shall be stored with security procedures and facilities in accordance with the provisions of the law for the period specified in the provisions under the Applicable Law in Indonesia.
We provide facility for You to delete Your Account in Our Platform and Features. If You wish to delete Your Account, You may choose the delete Account option which is available in the setting. In the event that You delete Your account, You consciously understand the consequences that You cannot use Features and Platform or other Our services because You are no longer registered as an active user. Please be informed that although You are no longer a registered active user of the Platform, Your Personal Data can still be stored for the required period based on the provisions of the Applicable Law.
We have the authority to remove Your own Account based on Our terms, based on court decree or judgment, and/ or in accordance with law. We shall notify You by email regarding the removal of Your Account under this authority.
We have the authority to remove Your Personal Data based on Your written request or at Our discretion, in the manner that We specify but remain subject to the Indonesian Applicable Law.

7. Limitation of Liability

You are responsible for security and implement appropriate measure in safeguarding Your Personal Data, such as, restricting access, creating strong passwords, protecting passwords, and/ or protecting One-Time Password (OTP).
We are not responsible for the exchange and/ or provision of Your Personal Data that You do personally, including what You do through the Platform.
Our Platform may contain links to other websites. In case you use such links, you should understand that We do not have any control on such websites and / or Platform, therefore you understand and warrant that we are not / shall not be held accountable on the privacy policies of the sites / Platform of the other third party, based on such links and recommend You to read the privacy policy of each site/ Platform You visit that collects Personal Data.
We are only responsible for the protection and security of Your Personal Data to the extent that Personal Data is stored in a system developed and managed by Us and We at any time shall perform and take any reasonable effort that is required to protect and safeguard Your Personal Data. By continuing to access the Platform, using Features, and / or other Our services, You waive the rights to file any claims, losses, demands and lawsuit that You may have in the event that failure of Personal Data protection arising from a part of negligence committed by Yourself in maintaining the security and confidentiality of Personal Data and/ or as a result of actions by third parties who attempt to obtain Personal Data unlawfully.
We are not responsible for the originality, authenticity, validity, accuracy, completeness of the Personal Data You provided.

8. Miscellaneous

We always try to provide the best services for You in accessing the Platform and using Our Features therefore We have the right to make changes to this Policy to perform adjustment for business developments and applicable legal provisions. Changes to this Policy shall from time to time be uploaded to the Platform so that You can read the changes from this Policy. If changes to this Policy are material to personal Platform data and information, We shall notify You before the changes take effect. By continuing to access the Platform, using Features, and/ or other Our services, You declare that You have read, understood and agreed to be bound by the changes of this Policy.
If any provision or part of this Policy becomes unlawful, unenforceable or invalid, then such provision or such part will deemed removed from this Policy and We will adjust such provisions in order to be enforceable according to the Applicable Laws, in which the other provisions of this Policy will remain effective.
In the event of a change of controller or a change in ownership of all or part of Our business, including the Platform, due to the performance of a merger, consolidation, acquisition, joint venture, transfer, bankruptcy, and/ or other corporate actions, Your Personal Data may/ shall be the part of the transfer based on such corporate actions.
This Policy can be translated into other languages other than Indonesian as provided by Us. It is possible that some parts of this Policy have different meanings, interpretation or definitions when translated into other languages. Should any differences occur in the interpretation between the Indonesian version and the other language version, the Indonesian version shall prevail and You are suggested to refer to the Indonesian version.

9. Contact Us

You may submit questions, critics and suggestions, complains, or report that related to Personal Data by contacting Us through email or call. All correspondence between You and Us will be kept in writing or recorded for Our interest.