1. Our Commitment to Your Privacy
1.1. PT Focus Inti Solusi ("FIS", "we", "us" or "our") is committed to protecting the privacy and security of your personal data, as defined under the Law of the Republic of Indonesia Number 27 of 2022 on Personal Data Protection, Government Regulation Number 71 of 2019 on the Implementation of Electronic Systems and Transactions, Regulation of the Ministry of Communication and Information Technology Number 20 of 2016 on Protection of Personal Data in Electronic Systems, and other applicable Indonesian laws regarding personal data protection ("Personal Data Protection Regulation").
1.2. This privacy policy and notice ("Policy") describes how we collect, maintain, use, disclose, process and safeguard your personal data and the personal data of any third-party individual, including any sensitive personal data, as may be voluntarily or required to be provided by you in the course of using our License/Service of the Software. This Policy also tells you about your rights and how applicable laws protect you.
1.3. This Policy supplements and is an integral part of the Terms of Service.
2. Your Consent Is Important
2.1. At FIS, we value your privacy and will protect your personal data as provided by you in the course of using the License/Service, in compliance with the laws of Indonesia, in particular the Personal Data Protection Regulation.
2.2. Before you use our licenses/services ("Licenses/Services"), please read this Policy in its entirety, as it is intended to help you make informed decisions about how we collect, use, and process your personal data.
2.3. FIS will only collect and use your personal data in accordance with applicable laws (including the Personal Data Protection Regulation), this Policy, and/or the privacy terms in any agreement you may have with FIS.
2.4. This Policy explains: what personal data we collect about you and how; how we use your personal data; the parties we disclose your personal data to; your rights in respect of your personal data; and the choices we offer, including how to access and update your personal data.
2.5. By providing us your personal data at our request or voluntarily, using our Licenses/Services, and/or ordering or purchasing any licenses/services, and communicating with us, you consent to our collection, use, processing, and disclosure of your personal data in accordance with this Policy.
2.6. If you provide us information on behalf of someone else, you represent and warrant that the other person has appointed you to act on their behalf, including to give consent to the processing of their personal data, to receive privacy notices, and to consent to the transfer of their personal data abroad (where applicable).
2.7. If you are a user of our Software, the provision of your personal data is voluntary. However, if you do not provide it, we will not be able to process your personal data for the purposes outlined in this Policy, which may result in us being unable to provide our Licenses/Services or accept payments from you.
3. Information Collection and Use
3.1. As part of using our Licenses/Services, we may need to collect, record, hold, use, disclose, and store ("process") personal data and financial information about you, including to establish your personal identification and background, and your financial standing and creditworthiness (where required).
3.2. We may, from time to time, collect the following personal data from you:
Contact Information — your name, alias, email address, mailing address, phone number, delivery address, and residential address.
Personal Identification Information — age, gender, nationality, date of birth, occupation, identity card or passport number.
User Account/Profile Information — username and password, purchases or orders, interests, preferences, feedback, and survey responses (for corporate users: company name, address, business type, owners, directors, and shareholders).
User-generated Content — photos, videos, audio, messages, reviews, customer service information, feedback or testimonials, or other content you publish on the Software.
Payment/Financial Information — bank account and payment details, shipping and billing information, and information about your transactions and purchases with us.
Device, Connection, and Usage Information — IP address, browser type and version, device type and operating system, pages visited, time of visit, and other diagnostic data.
Transaction Information — details of payments made by and to you, and services you have ordered or purchased.
Marketing and Communications Information — your preferences in receiving marketing material and communications from us.
3.3. The list above is not a definitive list of all personal data we collect. We will only collect personally identifiable information where necessary to provide our Licenses/Services to you.
3.4. We may obtain this information directly from you and from other sources, including through your relationship with us, verbal/written communications, third parties connected with you (partners, directors, shareholders, etc.) subject to your prior consent, and other related sources for which you have given consent.
4. Purposes of Processing Your Personal Data
We may use your personal data to: provide our Licenses/Services; perform our contractual obligations; administer your account; send bills, invoices, and receipts; process orders and payments; provide customer service and technical support; inform you of offers and promotions (you may opt out at any time); improve our services and develop new products; monitor, detect, and prevent fraud, spam, or malware; and comply with legal obligations, audits, and risk management.
Based on your consent, we have the right to use your photos, images, and recordings for marketing purposes without payment of royalty to you. If you disagree, please submit a written request to withdraw your consent; we will stop processing such personal data no later than 3×24 hours after receiving your request.
5. Disclosure of Your Personal Data
We may disclose your personal data (to the extent necessary) to: partners/service providers who assist us in providing our Licenses/Services; your advisers (accountants, auditors, tax consultants, lawyers, etc.) authorized by you; financial institutions and related payment service providers; government departments/agencies in connection with official investigations; our IT service providers; and other parties to whom you have given express or implied consent.
Your personal data may also be disclosed as part of a merger, acquisition, or sale of FIS's business assets; we will notify you before your personal data is transferred in such scenarios.
6. Disclosure for Marketing and Promotional Purposes
If you have given us permission, we may contact you by mail, phone, SMS, instant message, or email about services, promotions, or events that may interest you. We do not disclose, rent, or sell your personal data to third parties for direct marketing purposes. You may opt out at any time via the unsubscribe link or by writing to us.
7. Situations Under Which We Disclose Your Personal Data
We treat your personal data as confidential and will only disclose it where: you have given permission; we are required or permitted by law; required by court order or authority; or to meet our obligations to a relevant regulatory authority.
8. Data Security
We take reasonable security measures to protect your personal data from unauthorized access, use, or disclosure, and from loss of the storage media on which it is held. Your personal data is stored on secure servers located in Indonesia. We will not retain personal data longer than necessary for the purpose it was processed, and will securely destroy or delete it when no longer needed.
9. Your Obligation to Provide Complete Personal Data
You confirm that all personal data you provide is true, accurate, and complete. In the event of any change to your personal data, you will promptly notify us.
10. Your Right to Access and Correct Your Personal Data
You may access the personal data we hold about you by submitting a written request; we will provide a copy of the requested data within 21 business days. You may also request correction of personal data that is inaccurate, incomplete, or outdated.
11. Exercising Your Choices Regarding Your Personal Data
You may, at any time, access, correct, update, or request deletion of your personal data. Please contact us at:
Tel: +62 811 930 1359
Email: [email protected]
12. Transfer of Personal Data
We currently do not transfer your personal data outside Indonesia. Should this change in the future, we will ensure your personal data continues to receive a standard of protection at least comparable to that provided under the Personal Data Protection Regulation.
13. Personal Data from Minors and Other Individuals
Our License/Service is not intended for anyone under the age of 21, and we do not knowingly collect personal data from them. If you provide personal data of other individuals (spouse, family, business partners, etc.), you warrant that you are authorized to do so and have obtained their consent.
14. Enquiries or Complaints
Should you have any questions, concerns, or complaints regarding this Policy, please contact us at:
Tel: +62 811 930 1359
Email: [email protected]
15. Amendment and Language
FIS reserves the right to modify, update, or amend this Policy from time to time by posting the updated version on the Software, effective immediately. In the event of any conflict between the Indonesian and other language versions of this Policy, the English version shall prevail.
Address
Jl. Pancoran Timur Raya No 41, Pengadegan, Pancoran, Jakarta Selatan 12770, DKI Jakarta, Indonesia
Phone: +62 21 2753 3002