PT Interbat Privacy Policy
Effective from 1 Oktober 2024
We recognize that privacy is
everyone's rights that needs to be taken seriously, therefore, this Privacy
Policy will governs how we, PT Interbat ("We") may obtain, process,
and protect your personal data from our services or your interaction with us,
for example, your personal data which we may collect through your interaction
with this website www.interbat.co.id
(“website”).
'Personal data' means
all information relating to an identified or identifiable natural person, for
example, your personal identity, telephone number, email address, postal
address, or any other information within the scope of Personal Data Protection
Law.
This Policy is a form of our
commitment to comply with legal regulations related to personal data protection
in Indonesia, especially Law Number 27 of 2022 concerning Personal Data
Protection and its derivative regulations (‘Personal Data Protection Law’).
By accessing this website, you
understand and agree to the collection of your personal data, as well as how we
will use that personal data. In addition, our website may include links to
third-party websites but this is outside the scope of this Policy. Please
review the privacy policies of third-party websites for information about how
those third-party processes your personal data.
If you have questions or requests
regarding this Policy or requests regarding the rights to personal data, for
example, questions about how we process personal data from human resources
which is not covered by this Policy, then you can contact us via the contact
information that we have provided in the section “Contact Us" at the end
of this Policy.
Legal Basis for
Processing Your Data
Any processing activities of your
personal data will always be based on personal data processing according to the
legal regulations in force in the territory of Indonesia, including those that
we use as the basis for processing your personal data, which are as follows:
- Processing is based on
your valid consent for specific and lawful purposes;
- Fulfillment of
contractual obligations that we have with you; or
- Implementation of legal
obligations that we must comply with.
How We Obtain Your
Personal Data
We collect your personal data to
help improve our services in providing benefits to the health industry of our
business and provide you with an interesting experience when accessing the
website.
We may obtain information about
your personal data depending on how you interact with us and how you use our
services or accessing this website. We may obtain information about you,
including but not limited to:
- Personal identity such as
name, date of birth and nationality;
- Contacts such as address, email, telephone number;
- Usage data such as usage
history, website browsing history, and
cookies;
- Location such as access location, IP address,
workplace address; and
- Information required by law such as
Information We need to implement withdrawal protocols and/or
pharmacovigilance based on applicable legal regulations.
We may need other information or
specific personal data in the event of a specific request from you, in which
case we will ask for specific consent from you separately from this Policy,
before we can do so.
We can collect your personal data
information in several ways, including:
- Your information that we obtain directly from you;
- Your information that we obtain automatically using technology; or
- We obtain your information from third
parties.
In this case, if you submit
Personal Data that is not information related to you, then we will assume that
you have obtained consent from the party concerned to submit the Personal Data
to Us and to be processed by this Policy.
How We Use Your
Information
In principle, we collect
information about your personal data only for one or more specific and
legitimate purposes such as:
- Allow you to access
certain services and features on our website;
- Performing certain
procedures such as verifying your personal data to enable us fulfilling
any specific transaction with you;
- Maintaining consumer
support function for you, such as communication or investigations
necessary to resolve any consumers requests regarding the products and/or
services we might offer, including product replacement, information
and/or adverse drugs effect resolvement (if any);
- Support efforts to
improve our services and marketing strategies by analyzing your profile
and responses;
- To manage our day-to-day business
activities regarding your participation in our events (including your
visits to our booth), social media campaign, symposium, training or
seminars, sweepstakes or any other promotional activities or requests;
- To verify the authentic identity of the
person contacting us by telephone, electronic or other means;
- For internal training and quality
assurance purposes;
- To understand and assess consumer
interests, wants and changing needs, to improve our website, our current
products and services, and/or develop new products and services; and to
provide you with personalized products, targeted communications and
advertising and product recommendations;
- If necessary, to fulfill legal
obligations to regulators in the health sector, such as pharmacovigilance
and recall incidents; and/or
- for any other purpose with your further
consent.
When we collect and use your personal data for the purposes mentioned
above or for other purposes, we will notify you before or at the time of the
collection.
Where necessary, we will ask for your consent to process your personal
data. Where you have given your consent to the processing activities, you have
the right to withdraw your consent at any time and
We only collect Personal Data
information about you that is adequate and not excessive for the purposes for
which we process it. We try to be careful to ensure that personal data is
accurate and relevant, and if necessary for the purposes for which we process
it, we will ask for your consent to update it.
Retention of Data
We retain personal data about you
only as long as it is necessary to do so for the legitimate purposes stated
above and to the extent necessary to comply with our legal obligations (for
example, if we are required to retain your data to comply with applicable
laws), resolve disputes, and enforce our legal agreements and policies.
While retaining such personal
data, we make reasonable security arrangements to prevent unauthorized access,
collection, use, disclosure, copying, modification, destruction, or similar
risks.
Who We Share Your
Information With
We will share your personal data
with our affiliates, business partners, and third-party service providers when
it is necessary to:
(1) Third-party
service providers. To carry out your requests, respond to your inquiries,
fulfill your orders, and coupons, gift, or provide samples to you, enable you
to enter sweepstakes, or make various other features, services, and materials
available to you through our websites or any other marketing campaign (offline
and online), we share your personal data with third-party service providers who
perform functions on our behalf, such as companies that: operate our websites,
process payments, analyze data, provide customer service, postal or delivery
services, or other third parties who participate in or administer our
promotions. They have access to the personal data necessary to perform their
functions but may not use it for any other purpose. Furthermore, they must
process this personal data under this Policy and as permitted by applicable
data protection laws and regulations.
(2) Other
third parties. Your personal data will also be used by us or shared with
advertisers, advertising networks, advertising servers, social media networks
and traffic analytics companies or other third parties in connection with
marketing, promotions, data enrichment or other offers, and product
information.
(3) Business
transfers. Your personal data will be used by us or shared with our business
affiliate primarily for business and operational purposes. As We continue to
develop our business, We may sell or buy assets, subsidiaries or business
units. In such transactions, your personal data will generally be one of the
transferred business assets but will remain subject to the promises made in our
pre-existing Policy (unless, of course, you have agreed otherwise). If another
entity acquires us, our business or substantially all or part of our assets, or
assets related to our websites, your personal data will be disclosed to that
entity as part of the due diligence process and will be transferred to that
entity as one of the transferred assets. Also, if any bankruptcy or
reorganization proceeding is brought by or against us, all such personal data
will be considered our assets and therefore may be transferred to third
parties.
(4) Legal
disclosure. We may transfer and disclose your personal data to third parties:
(a) To
comply with a legal obligation;
(b) When
we believe in good faith that applicable law requires it;
(c) At
the request of a government authority conducting an investigation;
(d) To
detect and protect against fraud, or any technical or security vulnerabilities;
(e) To
respond to emergencies; or otherwise
(f) To
protect the rights, property, safety, or security of third parties, visitors to
this website, ourselves, or the public.
In cases like this, we will try
to protect the confidentiality and security of your information by requiring
our partners to also protect your personal data information, so that under
contractual obligations, the information will only be used on a limited basis
to complete matters to complete their services. Us and/or to comply with
applicable legal regulations.
Your Rights Regarding
Personal Data
Based on applicable legal
regulations, you have the right to your personal data information, but
regarding the right to object to one or more stages of personal data
processing, you can inform us about this intention via the contact listed in
"Contact Us" at the end of this Policy. However, when you do not give
us access to this information, this means that we will not be able to provide
one or more of our services to you.
Rights regarding your personal
data includes:
Request information regarding
clarity of identity, basis of legal interest, purpose of request and use of
personal data, and accountability of the party requesting personal data, such
as complete, update, and/or correct
errors/inaccuracies; gain access and obtain
copies; end processing, delete, and destroy
your personal data; withdraw consent to
processing; raise objections to
decision-making actions that are based solely on automated processing; delay/limit processing; submitting
complaint to the judicial court and receiving
compensation for violations; obtain, use, and
transmit your personal data; use and transmit
your personal data; and storage security.
We will try our best to maintain
the confidentiality and security of your personal data information that we
manage, through various technical, administrative, and procedural mechanisms
which are solely intended to maintain the confidentiality and security of your
personal data information from illegal access by third parties. Regarding your
personal data that is being managed by third parties, we strive to ensure that
the confidentiality and security of your personal data will be carried out by
this Policy and a separate agreement between us and the third party. However,
we cannot guarantee 100% that the preventive data that we have implemented will
always run well, for this reason, we cannot provide guarantees for the security
and confidentiality of your personal data, however, we will take legal action
against third-party partners. As if the leak of your personal data is the result
of the failure and/or negligence of that party.
Transfer of Data
Your information, including
personal data, may be transferred to – and maintained on – computers located
outside of your state, province, country or other governmental jurisdiction
where the data protection laws may differ from those of your jurisdiction.
If you are located outside
Indonesia and choose to provide information to us, please note that we transfer
the personal data to Indonesia and process it there.
Your consent to this Privacy Policy
followed by your submission of such information represents your agreement to
that transfer.
We will take all the steps
reasonably necessary to ensure that your data is treated securely and in
accordance with this Privacy Policy and no transfer of your Personal Data will
take place to an organization or a country unless there are adequate controls
in place including the security of your data and other personal information.
Age Restrictions
This website is not intended for
children aged 16 years and under. We never have the intention to collect
personal data from children aged 16 years and under. So, by accessing this
website, you consciously acknowledge that you are 16 years of age or older.
However if We somehow are able to identify you as an underage, then We will not
process any of your inquiries to us and immediately remove your data from our
system thereof.
Updates to Our Policies
If necessary, at any time, the
decision to change and/or update this Policy is our right as the service
manager, in this manner whenever we post changes, we will revise the “last
updated” date at the top of this Privacy Policy, and for this reason, we want
you to always read and review this Policy before using our services.
Contact us
Any questions or requests for
additional information related to this Policy, or even if you want to submit a
complaint regarding how we process personal data, you can always inform us at dpo@interbat.co.id, In addition,
please notify us if you have a request for correction of information in writing
via this contact. We may request information from you that allows us to verify
your identity before fulfilling your request. After verifying your identity, we
will respond to your request as soon as possible. If we cannot respond to your
request within 3 days, then We will notify you within that time, when we can
respond to your request.