Effective from [10 May 2022] We respect your right to privacy. This Privacy Policy explains how PT Power Cred Technologies, (hereinafter, “we”, “us”, or “PowerCred”) collects, uses, discloses, and secures information from or about you (hereinafter, “you” and “your” or “End User”). You can learn more about PowerCred’s Solution on the Website. By accepting this Privacy Policy, or by accessing and/ or using PowerCred’s Solution, you agree to be bound by this Privacy Policy. If you do not agree to (or cannot comply with) all of the terms that are set out under this Privacy Policy, you may not access or use PowerCred’s Solution. If you represent another Person, you hereby warrant that you have the authority, intention and capacity to accept this Privacy Policy on behalf of such Person. You authorize PowerCred and the Client to obtain, store, transmit, process, use and disclose the information collected from or about you in accordance with this Privacy Policy WE DO NOT SELL OR RENT PERSONAL INFORMATION THAT WE COLLECT. WE ONLY PROVIDE YOUR DATA TO CLIENT(S) AND PLATFORMS WHO YOU HAVE EXPRESSLY AUTHORISED TO RECEIVE YOUR DATA. Please read this Privacy Policy carefully:
- What Information We Collect.
- Information provided to us by you. We may collect information:
- when you authorize PowerCred (including through a Client Application) to collect information on your behalf or when you access or avail of PowerCred’s Offering in any other manner, we collect information provided by you, in connection with your use of/ access to PowerCred’s Solution, including:
- identifiers and login information as may be required for PowerCred’s Solution to connect to the Platform, such as your username and password, or a security token; and/or
- your or your business’s name, phone number, email address, physical address, one-time password (OTP) and any other details that may be required to verify your or your business’s identity for executing your request/instructions.
- other information as may be necessary to provide any part of PowerCred’s Offering, and the nature of the information will depend on the functionality and integration that you seek.
- when you are communicating with us in any manner, such as through customer support, our Website, or the Client Application. This may include, among other details, information such as your username, your email address, your date of birth, and your phone number.
- when you authorize PowerCred (including through a Client Application) to collect information on your behalf or when you access or avail of PowerCred’s Offering in any other manner, we collect information provided by you, in connection with your use of/ access to PowerCred’s Solution, including:
- Acquired data.
- We collect data from the Platform(s) that you authorize. Depending on the connected Platform and what information is requested by the relevant Client, this data may include, without limitation:
- information regarding your identity including your full name, gender, e-mail addresses, telephone phone number (including the type of phone), physical addresses, profile picture, profile introduction/ description, profile link/ URL, date of birth, affiliations, documents, licenses, and government IDs;
- information regarding your clients and suppliers, such as your transactions with them, demographic and other analytical information regarding your transactions with your clients and suppliers to the extent access to such information is generally available or provided by the Platform;
- your career, financial and income information including the name and nature of your business, the period for which it has been operational, the current status of operations, relevant dates, sources of income and revenue, currencies received, the quantum and form of income and revenue including details of all receivables (under whatever title), total income, income per Platform, financial account details including the name of your financial institution, the account type, account number, the account ownership, balance, branch number, International Bank Account Number (IBAN), Bank Identifier Code (BIC), routing number, sort code, account statements and details about your transactions, information about credit and loan accounts, including balances owed, payment amounts and dates, loan/ credit type, scheduled repayment dates, your transaction history, guarantor(s), credit limit, repayment status, and the rate of interest;
- information that we receive from your device including your IP address, your service provider, your device and browser details such as operating system and hardware model, time zone setting, device location;
- information we receive from other sources such as the Client, which would include information like your name, phone number, address, e-mail address, zip code, and financial information;
- information that can be used to gauge your reputation such as through customer reviews on various Platforms;
- information related to your advertisements and marketing activities on Platforms, including information that can be used to gauge engagement with your advertisement and marketing activities on Platforms such as follower count, view counts, save counts, likes and dislikes, content links/URLs, content types, timestamps, content description/ caption, number of impressions, your comments, ratings, stars, feedback, reviews, achievements, awards, rewards, and recognitions;
- information regarding the location of your business(es) including the latitude, longitude of the business location, the opening hours and closing hours, etc;
- your transactions (including information such as nature, volume and frequency) on e-commerce Platforms, cash-flows from such activities, revenues, refunds, the fees charged by you if you are a seller/service provider on such e-commerce Platform;
- your accounting information that may be stored on any Platform; and
- other information as may be necessary to provide any part of PowerCred’s Solution, and the nature of the information will depend on the functionality and integration that you seek.
- We also use cookies and similar tracking technologies to collect information. You can find more information about how we use cookies in Clause 6 below.
- We may acquire/ access your data or data about you or related to you from Platforms or other sources, from time to time, based on instructions from the Client.
- We collect data from the Platform(s) that you authorize. Depending on the connected Platform and what information is requested by the relevant Client, this data may include, without limitation:
- Information provided to us by you. We may collect information:
- How We Use Your Information. We use your data for several commercial and business purposes such as:
- To maintain, operate, and provide PowerCred’s Solution.
- To enhance, improve, modify, and develop PowerCred’s Solution and to develop new services.
- For statistics and analytics. We may use your data in an anonymised form to generate statistics that are not attributable to you personally or any Person in particular (for instance, we may publish a statistic that shows how many businesses of a particular category of goods/services are present in a given geographical area, or how many businesses use a particular service within a given geographical area), and we may publish these statistics on our Website and/or in our marketing material or any other manner.
- To track and analyse usage. We use the information to analyze how you use PowerCred’s Solution and to improve PowerCred’s Solution.
- To provide support and communicate to and with you, Clients or Platforms.
- To comply with contractual and legal obligations and compliances, and to protect against and/ or institute legal action.
- To protect the rights, privacy, safety, or property of the End User, Client, our partners, PowerCred, and others.
- To investigate any misuse of PowerCred’s Solution, and criminal activity or other illegal/ unauthorised access or use of PowerCred’s Solution and/or infrastructure (such as servers, computers, code, etc.).
- For other notified purposes with your consent.
- How We Share Your Information.
- We share your data for several purposes in the nature of business and commercial activity, including to enable functionality in PowerCred’s Solution. We will share your data as permitted by you when you opt to connect PowerCred’s Solution with any Platform. When providing information to us, you authorize PowerCred and the applicable Client to act on your behalf to obtain, store, transmit, process, use and disclose the information collected from or about you in accordance with this Privacy Policy. Some specific cases where we share your data include:
- With the Client(s) that you have authorised to receive your data from us;
- With a Platform based on your request;
- With a third party based on your request;
- With any authority (including a judicial, quasi-judicial or executive authority) or any Person (including professional advisors) as may be required for us to enforce a legal or contractual right/ duty/ obligation or defend against claims;
- With our data processors and other service providers, partners, or contractors in connection with the services they perform for us or for a Platform. This would include service providers such as those that provide us with analytics services, tools for internal collaboration and communications, user research and survey services, email services, CRM solutions, sales and marketing tools and solutions, event management, hosting, customer support, lead generation, document management, payment processing, cloud storage and data warehousing, legal services, fraud prevention, identity verification, and security services;
- To comply with applicable law, regulation, or legal process;
- In connection with a change in ownership or control of all or a part of our business;
- Between and among PowerCred and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership;
- With consultants and professional advisors of PowerCred who are legally and/or contractually required to maintain confidentiality;
- As we believe reasonably appropriate to protect the rights, privacy, safety, or property of End User, Client, our partners, PowerCred, and others; and/or
- With any other Person with your consent.
- We may collect, use, and share Anonymised Data, for any purpose including improvement/enhancement of PowerCred’s Solution, research and development etc.
- We share your data for several purposes in the nature of business and commercial activity, including to enable functionality in PowerCred’s Solution. We will share your data as permitted by you when you opt to connect PowerCred’s Solution with any Platform. When providing information to us, you authorize PowerCred and the applicable Client to act on your behalf to obtain, store, transmit, process, use and disclose the information collected from or about you in accordance with this Privacy Policy. Some specific cases where we share your data include:
- Platforms and Your Data.
- We do not assume responsibility for your data or the privacy policies of any Platforms supported by PowerCred’s Solution. We encourage you to carefully review the privacy policies of any Platform you chose to access or share your data with via PowerCred’s Solution. For your reference, the privacy policies of some of the Platforms which are currently supported by PowerCred are listed below:
- Instagram: https://help.instagram.com/402411646841720
- Google: http://www.google.com/policies/privacy
- PowerCred’s Solution uses the APIs of certain Platforms to connect to their services, if you wish to ensure that PowerCred’s Solution does not access data from a Platform you have previously connected to, you may follow the instructions provided by the Platform.
- We do not assume responsibility for your data or the privacy policies of any Platforms supported by PowerCred’s Solution. We encourage you to carefully review the privacy policies of any Platform you chose to access or share your data with via PowerCred’s Solution. For your reference, the privacy policies of some of the Platforms which are currently supported by PowerCred are listed below:
- Data Security. We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no security system is impenetrable, and we disclaim responsibility to that extent. We cannot guarantee the security of your data whether located on our databases or otherwise, nor can we guarantee that your information will not be intercepted while it is being transmitted to and from us, a Platform, a Client or any other Person.
- Cookies.
- We may collect information using cookies or similar technology. Cookies are small data files stored by your browser on the hard drive or memory of your device. Cookies enable us to personalize your experience, maintain a persistent session, passively collect demographic information, and monitor advertisements and other activities. They generally contain information such as website preferences, user settings, and browsing history and help us recognize you as you interact with or revisit PowerCred’s Solution.
- We use both first-party and third-party session cookies and persistent cookies:
- Session Cookies: We use session cookies to make it easier for you to navigate PowerCred’s Solution. These are cookies that terminate once you end your session.
- Persistent Cookies: A persistent cookie remains on your device for an extended period or until it is deleted. To the extent we provide a log-in portal or related feature, persistent cookies can be used to store your passwords so that you don’t have to enter them more than once.
- If you do not want us to place a cookie on your device, you may be able to turn that feature off on your device. How this is done will vary from browser to browser and device to device, you should be able to find if and how this is possible by reading the relevant documentation for your browser or by checking with the browser’s customer support. If you decide not to accept cookies from us, certain aspects of PowerCred’s Solution may not function properly or as intended.
- Our Retention Practices.
- We retain your data for no longer than necessary to fulfil the purposes for which it was collected and used, as described in this Privacy Policy, unless a longer retention period is necessary and legally permitted.
- Anonymised Data may be retained indefinitely by us.
- Your data may be retained by us if required by the applicable law.
- We will delete all data (other than publicly available data), provided that such deletion is legally permissible, in the following circumstances: (a) it is no longer required by us to provide PowerCred’s Solution, (b) termination of the end user agreement (if any) between you and PowerCred, (c) if you withdraw your consent based on which your data was collected by us. If you wish to request deletion of your data (other than Anonymised Data and publicly available data) you may request for the same at any time by contacting us in accordance with Clause 16 of this Privacy Policy. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.
- Should you request termination under the end user agreement (if any) between you and PowerCred, we will delete all your data (other than Anonymised Data and publicly available data).
- If you withdraw your consent, request deletion of data or terminate any agreement between us, we will no longer be able to provide you with one or more of PowerCred’s Solution.
- Transfer of your personal data outside of Indonesia
- The data that we collect from you will be maintained in accordance with data localization requirements under applicable law. We will take reasonable steps to ensure that your data is handled securely and in accordance with this Privacy Policy.
- The legal basis for processing personal data
- Our legal basis for the collection and processing of your data will depend on the information concerned and the context in which we collected or processed it. Unless otherwise stated we will only collect and process information where:
- it is necessary for the performance of a contract with you or the Client;
- you have given your consent to do so;
- to comply with our obligations under applicable law;
- the processing is necessary for our legitimate interests (such as, to provide or update PowerCred’s Solution), but never overriding your rights under law; or
- if and when it is necessary to protect the vital interests of you and/ or other end-users.
- Our legal basis for the collection and processing of your data will depend on the information concerned and the context in which we collected or processed it. Unless otherwise stated we will only collect and process information where:
- Children’s Privacy. Our services (including PowerCred’s Solution) do not knowingly collect, maintain, or use personal information from Minors without their guardian’s express consent. If we learn that we have collected any personal information from a Minor without the guardian’s express consent, we will delete such information and terminate their access to PowerCred’s Solution. If you are a guardian to a Minor and if it comes to your knowledge that the Minor has provided us with personal information without your consent, you should alert us at the contact information provided in Clause 16 of this Privacy Policy so that we can take prompt take action toward deleting necessary information and terminating the Minor’s account.
- Links to External Websites. Our website and services (including PowerCred’s Solution) may contain links to certain third-party websites. We do not have any control over the content, practices and policies of these third parties (including those relating to privacy) of any such third party. Accordingly, we disclaim any responsibility for the content, practices or policies (including those relating to privacy) of such third-party. You should check the applicable privacy policy and terms of service when visiting any third-party site or before availing of or purchasing their services or products.
- Do Not Track. We do not maintain a “Do Not Track” mechanism. Accordingly, we are unable to respond to requests for the same.
- Effective Date and Changes to the Privacy Policy. This Privacy Policy shall come into effect on the effective date that is specified above. This Privacy Policy will be updated from time to time. If any updates or changes take place, we will notify you of the same by posting the same on our Website and by email (if it is available to us), and the effective date for each update or change will be specified at the top of the updated or changed version of the Privacy Policy. You are encouraged to review the Privacy Policy whenever you access PowerCred’s Solution or otherwise interact with us so that you are up to date on our data privacy practices and the choices available to you. Your continued use of PowerCred’s Solution will be considered as deemed consent to the changes to the Privacy Policies made in accordance with this clause. We may be unable to provide PowerCred’s Solution to you if you do not accept the updated terms of this Privacy Policy.
- THIS PRIVACY POLICY DOES NOT DESCRIBE WHAT THIRD PARTIES (INCLUDING PLATFORMS AND CLIENTS) MIGHT DO WITH YOUR DATA. ALL THIRD-PARTY OFFERINGS, SERVICES, PROCESSES, ETC. ARE SUBJECT TO THAT THIRD PARTY’S POLICIES. ALL INFORMATION COLLECTED AND PROVIDED BY POWERCRED IS ON AN ‘AS IS WHERE IS’ BASIS. THE INSIGHTS, REPORTS, CONCLUSIONS AND ANALYSES PROVIDED BY POWERCRED ARE ENTIRELY BASED ON DATA THAT POWERCRED RECEIVES FROM END USERS/PLATFORMS/THIRD PARTIES AND AS SUCH POWERCRED MAKES NO REPRESENTATIONS OR WARRANTIES REGARDING THEIR ACCURACY, COMPLETENESS, OR CURRENTNESS AND DISCLAIMS ALL LIABILITY ARISING OUT OF ANY DECISIONS OR ACTIONS TAKEN BY THE CLIENT BASED ON THE DATA PROVIDED BY POWERCRED. POWERCRED TAKES NO RESPONSIBILITY REGARDING HOW THE CLIENT OR ANY THIRD PARTY USES YOUR DATA, REGARDLESS OF WHETHER THEY ACQUIRE YOUR DATA THROUGH POWERCRED OR NOT. IN CASE YOU NEED TO EXERCISE ANY OF YOUR RIGHTS AGAINST A PLATFORM/ CLIENT/ THIRD PARTY, YOU WILL NEED TO CONTACT THE RELEVANT PLATFORM/ CLIENT/ THIRD PARTY, AND YOUR RIGHTS IN RELATION TO THEM SHALL BE AS PER THE POLICIES AND PRACTICES OF THAT PLATFORM/ CLIENT/ THIRD PARTY. YOU SHOULD CAREFULLY REVIEW ALL LEGAL DOCUMENTATION, INCLUDING THE PRIVACY POLICIES OF EACH PLATFORM, THIRD PARTY AND CLIENT WITH WHOM YOU ENGAGE. FURTHER, POWERCRED MAKES NO REPRESENTATIONS OR WARRANTIES REGARDING ANY PLATFORM OR DATA BEING MAINTAINED BY ANY THIRD PARTY, ITS ACCURACY, COMPLETENESS, OR CURRENTNESS. POWERCRED MAY NOT HAVE ANY CONTRACTUAL RELATIONSHIP WITH ANY THIRD PARTIES MAINTAINING THE DATA THAT IS BEING ACCESSED USING POWERCRED’S SOLUTION, AND POWERCRED DOES NOT, AND SHALL NOT HAVE ANY OBLIGATION TO, MODIFY, VERIFY OR REVIEW ANY DATA.
- Contacting PowerCred. Should you require any clarification or assistance on this Privacy Policy, or if you have any queries regarding our data practices, you may reach out to us at the contact information provided below:
- This Privacy Policy forms a part of the end user agreement (if any) between End User and PowerCred and must be read with the end user agreement.
- Certain Defined Terms. Words used with the first letter capitalised have the meaning set out below.
- “ Anonymised Data” means the following data that has been anonymised by removing all personal / identifying information and information about the source of such data (whether or not aggregated with any other data): (i) data relating to your usage of any part or all of PowerCred’s Solution, (ii) any data provided by you, and (iii) End User Data.
- “ Client” means PowerCred’s client who is authorised by you to receive your data PowerCred.
- “ Client Application” means any portal (including a website, software, application, mobile application and/or software-as-a-service application) that the Client uses to interact with or access End User Data and which integrates with some or all aspects of PowerCred’s Solution.
- “ End User Data” means any data, information, and materials about you provided to PowerCred and/or the Client by you through PowerCred’s Solution or any Platform, or otherwise obtained by PowerCred, including without limitation, information about your Account (e.g., login credentials), your name, address, telephone number, email address, financial information/records (including without limitation, banking data, cash flow, accounting statements, loan data, repayment information, etc.), transaction information/records (including without limitation, purchase history, sales history, receipts, refunds, bill payments, payment methods and preferences, etc.), social media data (including without limitation, followers data, engagement data, views and like counts, demography data, reach, profile IDs, posts and captions, etc.), logistics and supply chain related information, service ratings, reviews, location(s), response and shipping times, etc.
- ” Privacy Policy” means this privacy policy.
- ” Minor” means an individual who is less than the minimum age prescribed under the law to provide consent or to enter into contracts, provided that in no event will such age be less than 16 years.
- ” Person” means any individual, partnership, limited liability partnership, limited liability company, body corporate, corporation, association, society, trust or other entity or organization, whether or not a juridical person.
- “ Platform” means any Person, including without limitation Persons providing services such as e-commerce, accounting, payments, social media, location data, etc.
- “ PowerCred’s Solution” means any software, service, solution, application or other offering provided by PowerCred and may include JavaScript programme, widget, PowerCred’s code, API, HTTP/HTTPS endpoints, API Key, Documentation, dashboards and related tools (if any), and any other thing provided by PowerCred.
- “Website” means https://www.powercred.io/ and such other websites as may be made available by PowerCred from time to time.