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Privacy Policy
Mobile Application SmartPresence

Through this Privacy Policy, PT Bima Sakti Alterra, its affiliates, companies associated with it, and jointly controlled entities (“We or Us or Our“) are committed to protecting and respecting any of your personal data or information when you use the service our SmartPresence mobile application (“Service”), both individuals and legal entities (“You or Your”).

By accessing the Service, you declare that any of your Personal Data is correct and valid data, You acknowledge that you have been informed and understand the provisions of this Privacy Policy and you give us your consent to obtain, collect, process, analyze, display, send, open , store, change, delete, manage and/or use such data for the purposes as stated in this Privacy Policy.

This Privacy Policy explains the Processing of Your Personal Data enforced by Us to protect Your Personal Data which is used and managed by Us. Specifically, this Privacy Policy contains the following provisions:

  1. Definition;
  2. Obtaining and Collecting Personal Data;
  3. Purpose of Processing Personal Data;
  4. Disclosure of Personal Data;
  5. Collection of Personal Data from Third Parties;
  6. Personal Data Security;
  7. Access, Correction and Update of Personal Data;
  8. Consent;
  9. Deletion/Destruction of Personal Data and Revocation of Consent;
  10. Third Party Platforms;
  11. Marketing and Promotional Materials; And
  12. Other Provisions.

This Privacy Policy applies to those of You who use the Service or facilities that we provide in Our Service. Please read this Privacy Policy carefully to ensure that you understand the provisions regarding Our Processing of Your Personal Data.

1. DEFINITION

Unless otherwise defined in this Privacy Policy, all capitalized terms used in this Privacy Policy have the following meanings:

  1. “Affiliate” is any company or other entity, which directly or indirectly, controls, is controlled by or is under joint control with Us.
  2. “You or Your” can refer to you as the party accessing our Services.
  3. “Personal Data” is any data that identifies or can be used to identify, contact, or track You, alone or in combination with other information, directly or indirectly, in Our electronic and/or non-electronic systems including but not limited to Your name, Your short name, Your nickname, residential address or citizenship, gender, occupation, telephone number, International Mobile Equipment Identity (IMEI), home address, Global Positioning System (GPS), email address, Your picture, identification number issued by government, date of birth, marital status, religion, bank details, information about You which You have provided to Us in a registration form, application form or other similar form and/or information about You which has been or may be collected, stored, used and processed by Us from time to time.
  4. “We or Us or Our” are PT Bima Sakti Alterra, as the provider of private electronic systems, which is the owner or responsible for the Service.
  5. “Contact Us” is a means that You can use to contact Us for the purposes of implementing this Privacy Policy.
  6. “Competent Authority” is an institution or agency that has authority based on applicable laws and regulations, including but not limited to; ministries, non-departmental agencies, courts, and/or law enforcement officials.
  7. “Processing“, depending on the context and the series of words used in a sentence, is the activity of obtaining and collecting, processing and analyzing, storing, Disclosure, Deletion and/or Destruction of Personal Data and/or other information.
  8. “Destruction” is an activity with the purpose to eliminating Your Personal Data, in whole or in part, in our electronic and non-electronic systems so that it cannot be accessed again at a later time.
  9. “Deletion” is an activity with the purpose to limiting the use of Your Personal Data, in whole or in part, in our electronic and non-electronic systems which can be accessed again at a later time for the purposes determined in this Privacy Policy.
  10. “Disclosure” or “Revealing”, depending on the context and sequence of words used in a sentence, is the display, announcement, transmission, dissemination, and/or disclosure of Your Personal Data and/or other information.
  11. “Third Parties” are parties, such as, among others; Competent Authorities, Our partners, contractors, vendors, agents, Our Affiliated companies.

2. OBTAINING AND COLLECTING PERSONAL DATA

  1. We obtain Your Personal Data depending on your use of our Services, the Personal Data we obtain includes but is not limited to:
    1. General Personal Data;
      1. Your name
      2. Your Phone Number
      3. Your email
    2. Sensitive Personal Data;
      1. Your financial data
      2. Your physical data (including your facial/facial shape)
  2. We obtain and collect Your Personal Data in the following ways:
    1. Submission directly by You, such as, among others:
      1. When you contact Us;
      2. When you update your Personal Data which has previously been stored by us;
      3. Fill out surveys sent by Us or other parties officially appointed to represent Us;
      4. Use features on the Service that require permission to access relevant data stored on your device.
      5. Using the services on the Service, including detailed transaction data, including the type, quantity and/or description of the product or service purchased, delivery address, payment channel used, number of transactions, date and time of transaction, as well as other transaction details ;
      6. Fill in payment data when You carry out payment transaction activities through the Service, including but not limited to bank account data, credit cards, virtual accounts, instant payments, internet banking, retail outlets; and/or
    2. Data recorded when You use the Service, including but not limited to:
      1. Real or approximate location data such as IP address, Wi-Fi location and geo-location;
      2. Data in the form of the time of each of your activities in connection with the use of the Service;
      3. Your usage data or preferences, including your interactions in using the Service, saved choices, and selected settings. The data is obtained using technology that creates and maintains unique identifiers;
      4. Device data, including the type of device used to access the Service, including hardware model, operating system and version, software, IMEI number, file name and version, language selection, unique device identifier, advertising identifier, serial number, movement information device, and/or mobile network information; and/or
      5. Log data, including records on the server that receives data such as the device’s IP address, date and time of access, application features or pages viewed, application work processes and other system activities, browser type, and/or site or third party services that you use before interacting with the Service.
    3. Data obtained from other sources, including but not limited to data in the form of emails from marketing service providers.
    4. Acquisition and collection from Third Parties that store Your Personal Data; And
    5. Acquisition and collection by other ways and from any sources as available and as long as not prohibited by applicable laws and regulations.
  3. You hereby acknowledge and agree to provide and allow Us to obtain and collect Your Personal Data and/or other related data or information referred to letter a above for the purposes determined in this Privacy Policy.
  4. You must always ensure that the Personal Data You submit to Us is Personal Data that is true, complete, accurate and not misleading. You must notify us if there are changes to your Personal Data before the changes become effective, or in accordance with the provisions stipulated in the agreement You have agreed with us which regulates changes to Personal Data. Any incompleteness, invalidity, inaccuracy, and/or misleading of Your Personal Data submitted to Us may constitute a failure to comply with legal requirements. Furthermore, you hereby release Us from all consequences arising from your negligence or error in maintaining the truth, completeness and accuracy of your Personal Data, and your failure to maintain the validity, completeness and accuracy of Personal Data submitted to Us.
  5. In submitting Personal Data, you hereby represent and guarantee that you are a legally competent party to submit Personal Data to Us, and if:
    1. You are an individual who is not yet 21 (twenty one) years old and have never been married, then We assume that the submission of your Personal Data has been approved by Your parent, trustee or legal guardian on Your behalf;
    2. You are a party in the form of a body or entity, then We assume that the submission of Your Personal Data was carried out by an authorized representative to submit your Personal Data to Us, such as, among others; proxy or director; And
    3. You are a legally competent individual but the submission of Your Personal Data is represented by an authorized representative, so we assume that the submission of Your Personal Data is carried out by the authorized agent that You legally appoint to represent You.

3. PURPOSE OF PROCESSING PERSONAL DATA

  1. We may use Personal Data obtained and collected from You as mentioned in the previous section for the following:
    1. Providing features to provide, realize, maintain and improve our products and services.
    2. Sending information that we consider useful to You, namely information about our services or third parties that collaborate with Us, updates, developments and/or improvements to Our services or facilities.
    3. Personalization of Services for Your maximum benefit provided by Us and/or Third Parties that have collaborated with Us.
    4. Our compliance with obligations imposed by the Competent Authority or applicable laws and regulations as advised, recommended, expected or requested to do so by Our legal advisor and/or Competent Authority, which includes disclosures made in accordance with summons, decisions and/or court orders, orders from law enforcement authorities in the context of investigations or other legal processes or requirements that apply to us or our affiliates.
    5. Process Your request regarding access, correction, updating, and/or deletion/destruction of Your Personal Data in our system, as well as to contact You regarding Your request to Us.
    6. Other purposes as long as these purposes are not prohibited by applicable laws and regulations. To avoid doubt, we will inform You about these other purposes when asking for Your consent, unless otherwise determined by applicable laws and regulations.
    7. Helping you when communicating with our customer service, including to:
      1. Check and solve your problem;
      2. Direct your inquiry to the appropriate customer service representative to resolve the issue;
      3. Contact you via email, letter, telephone, fax, and other communication methods, including but not limited to, to assist and/or complete the problem resolution process, as well as provide news or other notifications regarding the protection of Your Personal Data by Us, including failures protection of Your Personal Data;
      4. Use information obtained from you for the purposes of research, analysis, product development and testing to improve the security of services on the Service, as well as develop new features and products; And
      5. Inform you regarding products, services, promotions, studies, surveys, news, latest developments, events and other information, both through the Services and through other media. We may also use this information to promote and process contests and lottery, provide prizes, and present relevant advertising and content about Our services and business partners.
    8. In certain circumstances, we may need to use or disclose Your Personal Data for law enforcement purposes or to fulfill the requirements and obligations of applicable laws and regulations, including in the event of a dispute or legal process between You and Us, or suspected criminal acts such as fraud or data theft.

4. DISCLOSURE OF PERSONAL DATA

  1. We sometimes have to disclose Your Personal Data for the following purposes and other purposes permitted by applicable laws and regulations:
    1. Fulfill obligations, responsibilities or orders arising from applicable laws and regulations or orders from the Competent Authority including but not limited to; the need for an inquiry, to fulfill a court order regarding a legal process, or to comply with archiving or reporting obligations based on a regulation, and for other purposes as required by the applicable regulations.
    2. Carry out public interests. We may provide your Personal Data to the Competent Authority and/or other parties appointed by the Competent Authority, for purposes, including but not limited to; contact tracing, supporting the Competent Authority’s initiatives, policies or programs, and other purposes as reasonably required.
    3. Consolidation, merger, acquisition, restructuring activities, the implementation of which involves Us as the party carrying out these activities with another party or another company or Us as the party being merged or merged with another company or acquired by another company.
    4. Use of Personal Data carried out by Third Parties in the context of providing, testing, research, analysis, sales, marketing, offers, or improving the quality of Our products or Service. Third parties who collaborate with Us, in which cooperation the third party requires the sending and/or disclosure of Your Personal Data. These products or services include the following: marketing services and providing services that handle complaints.
    5. Carrying out cooperation with third parties with the purpose of (i) assisting Us in providing our services; (ii) operate Our business; (iii) for the purposes of data processing on Our behalf; (iv) marketing, and (vi) other purposes as long as they are not prohibited by applicable laws and regulations. All Third Parties who work with Us are committed to processing the Personal Data they receive from Us in accordance with applicable laws and regulations.
  2. In connection with the disclosure of Your Personal Data to third parties, including from third parties to other parties, We will require these third parties and other parties to maintain the security and confidentiality of Your Personal Data in accordance with the provisions of applicable laws and regulations. If the relevant Third Party does not require certain Personal Data to be associated with You, Your relevant Personal Data will be appropriately deleted so that the Personal Data cannot be associated with You as an individual before it is disclosed or transferred to that Third Party. However, these other third parties will only manage and/or utilize Your Personal Data in connection with one or more purposes as regulated in this Privacy Policy and in accordance with the provisions of applicable laws and regulations.

5. COLLECTION OF PERSONAL DATA FROM THIRD PARTIES

  1. We may also collect Your Personal Data from third parties who collaborate with Us. In such cases, We will only collect Your Personal Data for purposes involving the third party or for the purpose of carrying out Our collaboration with the third party.
  2. In the terms of  We receive Your Personal Data from a third party, We consider that the submission of Your Personal Data to us by the third party has been previously approved by You so that we cannot be held responsible in any form if the third party submits Your Personal Data without Your consent before.
  3. Our Services may contain links to Third Party sites. We are not responsible for the acquisition, collection, processing, analysis, use, storage, display, announcement, transmission, distribution, deletion and destruction of Your Personal Data by such Third Parties. If You provide information directly to that site, the privacy policy and terms of service on that site will apply, and We are not responsible for the information processing activities or privacy policies of that site.

6. PERSONAL DATA SECURITY

  1. We will protect and secure Your Personal Data, which is stored in our storage system (which includes limiting access to Your Personal Data to our employees on a need to know basis. Processing of your Personal Data will only be carried out in a manner that is permitted and required to safe your Personal Data confidentiality) from Personal Data Processing actions by unauthorized parties and from Personal Data Processing actions that are contrary to applicable laws and regulations, accidental loss, destruction and damage or similar unintentional risks by taking and implementing reasonable legal, organizational and technical measures.
  2. Storage of Personal Data by Us:
    We will store your Personal Data in Our storage system, as long as:
    1. Retention of your Personal Data is necessary to fulfill the purposes as intended in this Privacy Policy;
    2. Storage of your Personal Data is permitted or required by applicable laws and regulations;
    3. During the retention period that we determine and is permitted by applicable laws and regulations;
    4. You do not request deletion/destruction of Your Personal Data that we store or You do not revoke Your consent for Us to store Your personal data; and/or
    5. We have rejected Your request for deletion/destruction of Your personal data that We store based on the considerations determined in this Privacy Policy.
  3. Personal Data stored by Competent Authorities:
    1. We may be required by applicable laws and/or the Competent Authority to send or share Your Personal Data to the Competent Authority and/or other parties appointed by the Competent Authority.
    2. In connection with point (i) above, You hereby agree and acknowledge that the storage of Your Personal Data by the Competent Authority and/or other parties appointed by the Competent Authority will follow the data storage policies and standards implemented by the Competent Authority and/or other parties appointed by the Competent Authority.
    3. You hereby acknowledge and agree that We are not responsible for the security and confidentiality of Your Personal Data stored by the Competent Authority and/or other parties appointed by the Competent Authority, and release Us from any claims relating to breaches of security and confidentiality of Personal Data You are kept by the Competent Authority and/or other parties appointed by them.
  4. Precautionary principle:
    1. We strongly urge You to be very careful to maintain the security and confidentiality of Your Personal Data, by, among other:
      1. Carefully attent to the media You use to store, upload, convey, send and/or share Your Personal Data; And
      2. Apply the precautionary principle by at least signing a confidentiality agreement with the party You entrust to receive and store Your Personal Data, or require that party to have and implement a privacy policy/notice that does not conflict with applicable laws and regulations, and only entrust the storage of Your Personal Data to parties who have credibility and integrity in protecting Personal Data.
    2. Use of the internet network: You need to know that the use of the internet network for sending, sharing, uploading or conveying Your Personal Data is not completely safe, considering that the internet network can be accessed by any party and there are risks associated with the provision and use of the internet network located in beyond our control and supervision. Your provision of Personal Data will be at Your own risk. Please always be careful in utilizing the internet network for the purposes of your Personal Data whenever You use the internet network.
  5. Exclusion of liability: We cannot be held liable in any way for:
    1. Security and confidentiality of Your Personal Data that You store yourself or that You submit to Third Parties or other parties;
    2. Security and confidentiality of Personal Data that has been disclosed to the public or a third party, whether the disclosure was made by You or any party other than Us, and the disclosure occurred not because of Our negligence or error in protecting Your personal data;
    3. All consequences arising from Your negligence in maintaining the security and confidentiality of Your Personal Data; And
    4. All consequences arising from the use of any media that You use to store, upload, convey, transmit and/or share Your Personal Data, such as, among others; internet network and cloud storage services.
  6. We protect any of Your Personal Data stored in its system, as well as protecting that data from unauthorized access, use, modification, retrieval and/or disclosure by using a number of security measures and procedures.
  7. Your Personal Data may also be stored or processed outside the country by parties working for Us in other countries, or by Our third party service providers, vendors, suppliers, partners, contractors or affiliates. In that case, We will ensure that the Personal Data remains protected in accordance with our commitment in this Privacy Policy.
  8. Although We have used our best efforts to secure and protect Your Personal Data, please be aware that data transmission over the Internet is never completely secure. Thus, We cannot guarantee 100% security of data provided or sent to Us by You and providing information by You is at Your own risk.
  9. We will delete Your Personal Data under our control if (i) Your Personal Data is no longer needed to fulfill the purpose for which it was collected; (ii) has passed the retention period in accordance with the provisions we determine; and/or (iii) storage is no longer required for the purposes of compliance with applicable laws and regulations.
  10. Please note that there is still a possibility that some of Your Personal Data is stored by other parties, including authorized state agencies. In the event that We share your Personal Data with authorized state administration agencies and/or other agencies that may be appointed by the authorized government or have collaboration with Us, you agree and acknowledge that the storage of your Personal Data by these agencies will follow their respective data storage policies.

7. ACCESS, CORRECTION AND UPDATE OF PERSONAL DATA

  1. You can ask us to:
    1. provide Your Personal Data and/or give You access to Your Personal Data stored in Our storage system;
    2. correct Your Personal Data stored in Our storage system; and/or
    3. update Your Personal Data stored in Our storage system.
  2. In the event that we provide Your Personal Data to You, We will provide this electronically and We will provide Your personal data in electronic form or by other means and other forms as We determine from time to time.
  3. We have the right to refuse Your request as intended in letter a above, in whole or in part, if:
    1. Your request is not relevant to Your Personal Data stored by Us, such as, among others; if You request Personal Data from another party where You do not have authority over the Personal Data; and/or
    2. We are not permitted by the Competent Authority and/or applicable laws and regulations to carry out Your request.
  4. You are obliged to update Your Personal Data, if You make changes to Your Personal Data that You have submitted to Us. We need You to update Your Personal Data for the purposes of Personal Data security and relevance.
  5. We may charge You an administration fee for handling Your request to access or correct Your Personal Data.
  6. You can withdraw the consent that You have provided regarding the processing of Your Personal Data under Our control by sending the request in writing through Our customer service as listed in this Privacy Policy. We will process Your request within a reasonable time since the request to withdraw consent is submitted, and will not process Your Personal Data in accordance with your initial request, unless required by applicable laws and regulations.

8. CONSENT

  1. By agreeing to the Privacy Policy, You acknowledge and state that you have read and understand the provisions of this Privacy Policy. Specifically, You give us consent to process Your Personal Data in accordance with the provisions of this Privacy Policy.
  2. You are deemed to have given your consent to the application of this Privacy Policy to You if one or more of the conditions below occur:
    1. You visit and/or use Our services and/or use the facilities We provide;
    2. You submit your Personal Data to Us for the purposes of Processing Your Personal Data as intended in this Privacy Policy;
    3. Your Personal Data is stored in Our storage system; and/or
    4. communicate with Us.
  3. This Privacy Policy comes into effect from the time You give Your consent to this Privacy Policy, either expressly or in the ways mentioned in letter b above, and will continue to apply as long as one of the conditions mentioned in letter b above lasts or until You withdraw your consent.
  4. If you are given the option to share Your Personal Data with Us, You can always choose not to do so. If We have asked for Your consent to Processing and You later choose to withdraw Your consent, We will respect that choice in accordance with Our legal obligations. However, choosing not to share Your Personal Data with Us, may mean that We are unable to carry out the actions necessary to achieve the purposes of Processing Personal Data as determined in this Privacy Policy or that You are unable to use the Services.

9. DELETION/DESTRUCTION OF PERSONAL DATA AND REVOCATION OF CONSENT

  1. Your data collected by Us will be stored securely in accordance with applicable laws and regulations in Indonesia. We will retain Your data for as long as necessary to fulfill the purposes described in this Privacy Policy.
  2. You have the right to withdraw Your consent for Us to store Your personal data and by withdrawing that consent, We will delete/destroy Your Personal Data from our storage system and stop processing Your personal data.
  3. Apart from the provisions in letter a above, Your Personal Data can also be deleted/destroyed from Our storage system, if:
    1. Stop using or subscribing to Our Services. To ensure availability and backup of data, We will perform the Deletion/Destruction of Your Personal Data no later than 1 (one) year after We receive notice of termination of subscription to Our Services;
    2. Your Personal Data is no longer needed and Deletion/Destruction of Personal Data is permitted by applicable laws and regulations;
    3. You ask us to delete/destroy Your personal data stored in our storage system, either partially or completely, by sending a written request to our contact; and/or
    4. We are prohibited from storing your Personal Data based on applicable laws and/or orders from the Competent Authorities.
  4. We have the right to refuse Your request for deletion/destruction of Your Personal Data, as intended in letter a above, either in part or in whole, if:
    1. We have deleted/destroyed your Personal Data in our storage system based on Your previous similar request, and/or a request from the Competent Authority to Us;
    2. Your request is not relevant to Your Personal Data stored by us, such as, among others; if You request Personal Data from another party where You do not have authority over the Personal Data; and/or
    3. We are not permitted by the Competent Authority and/or applicable laws and regulations to carry out Your request.
  5. In connection with the deletion/destruction and revocation of this consent, You hereby agree that You release us from responsibility in any form for all consequences arising from the deletion/destruction and revocation of said consent.

10. THIRD PARTY PLATFORMS

  1. You need to know and understand that our Services may contain links to Third Party platforms, such as, among others; advertisements or widgets which, if You click, may take You to a Third Party platform.
  2. You acknowledge and agree that the Third Party platform is managed and operated independently by the Third Party, and We will be released from any responsibility for the Processing of Your Personal Data by the Third Party, as intended in letter a above.
  3. If You provide your Personal Data to a Third Party through this Third Party platform, You agree that the privacy policy/notice and terms of service on that platform will apply, and We will be released from any responsibility for the Personal Data Processing activities carried out by that Third Party or which is regulated based on the privacy policy/notice and terms of service on the platform.

11. MARKETING AND PROMOTIONAL MATERIALS

  1. In connection with Your use of our services, You agree that We and/or third parties who collaborate with Us may use identification technology to collect Your personal data for purposes that are not prohibited by law.
  2. You agree that We and/or third parties who collaborate with Us can send You direct marketing and promotional materials such as; advertising and/or promotional communications, via email or other means of communication as available.
  3. You have the right to choose not to receive marketing and promotional materials to Your email or contacts, as intended in letter b above, by:
    1. pressing the unsubscribe button on marketing and promotional materials You receive;
    2. disable notification and location services from Your device; and/or
    3. contact Us and convey Your objections regarding sending marketing and promotional materials to Your email or contact.

12. WAIVER

This Privacy Policy includes a specific waiver for face structure data. Regarding your face structure data, the following provisions shall apply:

  1. Disclosure to Third Parties.
    Regarding the disclosure of Personal Data to Third Parties, face structure data is excluded.
  2. Deletion/Destruction.
    In the event you stop using or subscribing to our Services, face structure data will be deleted/destroyed no later than 3 (three) months after we receive notice of termination of subscription to Our Services.

13. OTHER PROVISIONS

  1. Change:
    1. We can review and change this Privacy Policy at our own discretion to ensure that the provisions in this Privacy Policy are consistent with Our future developments, and/or if there are changes to statutory regulations and/or orders from the Competent Authority for Us to change provisions in this Privacy Policy.
    2. We will notify You of the changes as referred to in point i above via public notification on our service, or via special notification to Your email address or Your contact registered in Our system.
    3. You agree that You are solely responsible for reviewing this Privacy Policy periodically to find out the latest information regarding this Privacy Policy through Our Services and/or on Your email and/or contacts registered on Our Services. Please periodically and regularly visit Our services so that You can be informed about Our Privacy Policy from time to time.
    4. With you stay:
      1. You visit and/or use our services and/or use the facilities We provide;
      2. You submit Your Personal Data to Us for the purposes of Processing Your Personal Data as intended in this Privacy Policy;
      3. Your Personal Data is stored in Our storage system; and/or
      4. communicate with Us.
    5. means that You agree to the changes that we have implemented.
    6. You are obliged to ensure that Your contact that You register with Us is correct and always active to avoid failure in delivering notifications to You.
  2. Invalidity: The invalidation of a provision in this Privacy Policy due to the enactment of a statutory regulation or other reason will not automatically cancel the validity of the other provisions in this Privacy Policy.
  3. Contact Us: If You have questions or complaints regarding the implementation of this Privacy Policy, you can contact Us via our contact details listed below:
    1. Telephone number: +62361 4785050 / +6281 138008800;
    2. Email: info@bsa.id
  4. Language: The Privacy Policy is written in Indonesian
  5. Applicable Law: All provisions in the Privacy Policy are subject to and interpreted in accordance with applicable law in the territory of the Unitary State of the Republic of Indonesia.
  6. Version: This Privacy Policy was last updated on July, 19th 2024. Please check this Privacy Policy periodically for any changes.

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  • 081238189460
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