EPMT

Effective as of January 1, 2025

We are PT Enseval Putera Megatrading Tbk, acting as the Personal Data Processor of PT Media Komunika Teknologi, which is part of the Kalbe Group and/or other companies within the Kalbe Group and/or affiliates and/or designated business partners (hereinafter referred to as “We/Us”), who are committed to protecting the interests and convenience of Customers, including compliance with Law Number 27 of 2022 on Personal Data Protection (hereinafter referred to as the “PDP Law”) and other applicable regulations related to Personal Data Protection in Indonesia.

This Privacy Policy explains information related to the processing of your Personal Data carried out by Us, including collection, recording, processing, analysis, display, transfer, disclosure, storage, alteration, deletion, and/or any other form of management related to your Personal Data, as part of our compliance with the PDP Law and other applicable laws on Personal Data Protection in Indonesia.

By accessing the website, application, or platform provided by PT Enseval Putera Megatrading Tbk, you acknowledge that you have read and understood all forms of processing related to your Personal Data.

By clicking “Agree” during the account registration process or data collection through the consent form provided to you, you are deemed to have consented and granted us permission to process your Personal Data.

  1. Legal Basis and Applicable Regulations

    The applicable laws and regulations of the Republic of Indonesia governing Personal Data Protection, as set out in the PDP Law and its implementing regulations. We comply with all laws and government regulations of the Republic of Indonesia concerning Personal Data Protection.

  2. Lawful Basis for Processing Personal Data

    Your Personal Data that we process must meet the following conditions:
    a. We have obtained your explicit and valid consent to use your Personal Data in accordance with our processing purposes through customer consent;
    b. We fulfill and exercise our rights and obligations in processing Personal Data in compliance with applicable laws and regulations; and/or
    c. We carry out processing with due regard to your rights as the Data Subject, as stipulated in the customer consent.

  3. Purposes of Processing Personal Data

    In general, we store and use the Personal Data you provide for the purpose of delivering products and improving our services to you, including but not limited to:
    a. Processing transactions/orders: Delivering products, providing shipping information, customer support, and transaction verification. We use account data for transaction processing, your email address for notifications and communication, and your registered address for product delivery.
    b. Providing services: Identifying you as a user, understanding your experience, conducting surveys, providing relevant information, analyzing activity trends, and creating recommendations and personalization. For this, we collect identity data, search data, cookies, real location data, and your usage history.
    c. Marketing and research analysis: Providing offers and advertisements relevant to you. For this, we collect search data, cookies, IP addresses, and your usage history.
    d. Communicating with you: Using various channels to provide information about Kalbe Group services and respond to your requests. For this, we process your email address, account ID, name, and registered address.
    e. Legal compliance and fraud prevention: Using identity, contact, transaction, and account profile data.
    f. Disclosure and sharing: Sharing your information under circumstances permitted by law and/or with your consent.

  4. Types of Personal Data Collected

    The Personal Data we collect includes, but is not limited to:
    a. Identity data: Name, gender, date of birth, nationality;
    b. Contact data: Address, email, phone number;
    c. Biometric data: Standardized security level, retained for a maximum of one year;
    d. Account data: Secured through encryption and anonymization; non-active/unused data will be deleted or anonymized as necessary;
    e. Transaction data: Purchase transactions and receipts;
    f. Technical data: IP address, cookies, device ID;
    g. Profile data: Account name, account ID;
    h. Usage data: Usage history, search history on our website, platforms, and applications;
    i. Real or approximate location data: GPS, Wi-Fi location, etc.;
    j. Additional data: Photos or other uploaded media;
    k. Health data: Health records, limited to authorized entities requiring such data.

  5. Duration of Processing

    a. We will continue processing as long as you remain our customer and continue to use our products, services, and/or facilities in compliance with applicable laws;
    b. We may retain your Personal Data as long as necessary to achieve the purposes stated in this Privacy Policy; and
    c. We may store your Personal Data outside Indonesia, subject to compliance with Indonesian law.

  6. Retention Period of Personal Data

    a. We will retain your Personal Data for five (5) years. After this period, your Personal Data will enter a retention phase and will be deleted if no longer required for processing purposes.
    b. If retained data is still required, retention may be extended for another five (5) years.
    c. If you close or request closure of your account, we will delete your Personal Data, unless otherwise required by law.

  7. Sources of Data Collection

    Personal Data is collected from, but not limited to:
    a. Data provided by you directly or indirectly;
    b. Data submitted during account registration on our websites, applications, or platforms;
    c. Data automatically recorded when using our websites, applications, or platforms;
    d. Data recorded when contacted by us through communication channels, with your consent;
    e. Data collected by third parties in compliance with applicable laws.

  8. Your Rights as a Data Subject

    You, as the Data Subject, have the following rights:
    a. Right to Information – To know what Personal Data we process, the legal basis, and purpose of its use;
    b. Right to Rectification – To complete, update, or correct inaccuracies in your data;
    c. Right of Access/Copy – To access or obtain a copy of your Personal Data, subject to applicable laws. Any costs incurred may be borne by you;
    d. Right to Erasure – To request deletion of your Personal Data, except when needed for:
    • National defense and security;
    • Law enforcement;
    • Public interest in state administration;
    • Supervision of financial, monetary, payment systems, and financial stability;
    e. Right to Withdraw Consent – To withdraw consent, with the understanding that it may affect our ability to provide products or services;
    f. Right to Object – To object to decisions based solely on automated processing, including profiling, that may have legal or significant effects;
    g. Right to Restriction – To delay or limit processing of your data proportionally, acknowledging potential impacts on service delivery;
    h. Other Rights – Any other rights provided under Indonesian law.

  9. Disclosure and Sharing of Personal Data

    We may share your Personal Data with the following parties for specific purposes:
    a. Group companies – For daily operational support and service quality;
    b. Service providers – For infrastructure, system security, marketing, etc.;
    c. Payment processors – For secure and legitimate payment processing;
    d. Advertising partners – For delivering relevant advertising;
    e. Marketing partners – For promoting our products and services;
    f. Academic researchers – For statistical and academic studies, in pseudonymized form;
    g. Law enforcement and authorities – To meet legal obligations such as national security, litigation, investigation, or vital interests;
    h. Business buyers – In the event of a business sale or negotiation, subject to prior notification.

  10. Personal Data Security

    As part of our commitment to protect your Personal Data, we implement the following:
    a. Providing best efforts to secure your Personal Data, while acknowledging risks beyond our control;
    b. Recommending that you safeguard confidential information (passwords, OTPs, PINs, etc.) and maintain device security;
    c. Ensuring third-party data processing complies with this Policy and related agreements, while taking legal measures against breaches;
    d. Acknowledging that third-party platforms may have independent policies beyond our control;
    e. Notifying you in the event of force majeure incidents beyond our control.

  11. Updates to the Privacy Policy

    We may update or amend this Privacy Policy from time to time. We will notify you of significant changes, but you are advised to regularly review this Policy. Continued use of our services after updates constitutes your acceptance of the changes.

  12. Contact Us

    We are committed to protecting your Personal Data as our valued customer.

    For further inquiries regarding this Privacy Policy, please contact our customer service at:
    customercare@enseval.com

    Thank you for your trust and loyalty in using our products, services, and solutions.