Privacy Policy

The existence of this Privacy Policy is a real commitment from Sobatinfo to respect and protect any data or personal information of users of the site , its derivative sites, and the Sobatinfo mobile application (hereinafter referred to as the “Site”). 

This Privacy Policy (along with the terms of use of the Sobatinfo site as stated in the Terms & Conditions and other information listed on the Site) establishes the basis for obtaining, collecting, processing, analyzing, displaying, sending, opening, storing, changing, deleting and/or or any form of management related to data or information that identifies or can be used to identify Users that Users provide to Sobatinfo or that Sobatinfo collects from Users or third parties (hereinafter referred to as “Personal Data”).

By clicking “Register” (Register) or a similar statement available on the Site registration page, the User declares that each User’s Personal Data is true and valid data, the User acknowledges that he has been notified and understands the provisions of this Privacy Policy and the User gives consent to Sobatinfo to obtain, collect, process, analyze, display, transmit, open, store, modify, delete, manage and/or use the data for the purposes stated in the Privacy Policy.

  1. Acquisition and Collection of User Personal Data
  2. Use of Personal Data
  3. Disclosure of User Personal Data
  4. Cookies
  5. User Choice and Transparency
  6. Security, Storage and Deletion of User Personal Data
  7. Access and Correction of User Personal Data or Withdrawal of Consent
  8. Complaints regarding User Personal Data Protection 
  9. Contact us
  10. Retention, Application of Data Subjects and Deletion of Information
  11. Privacy Policy Update

A. Acquisition and Collection of User Personal Data

Sobatinfo collects User Personal Data for the purpose of processing User transactions, managing and expediting the process of using the Site, as well as other purposes as long as permitted by applicable laws and regulations. The User data collected is as follows:

  1. Data submitted independently by the User, including but not limited to data submitted when the User:
    1. create or update a Sobatinfo account, including username, email address, telephone number, password, address, photo, and other information that can identify the User;
    2. carry out store verification, including, among others, Identity Card (KTP) and/or Taxpayer Identification Number (NPWP).
    3. contact Sobatinfo, including through customer service;
    4. fill out a survey sent by Sobatinfo or other parties officially appointed to represent Sobatinfo;
    5. interact with other Users through message features, product discussions, reviews, ratings, Resolution Centers (as defined in the Terms and Conditions) and other interactive features (either one or two ways) contained on the Site;
    6. use the services on the Site, including detailed transaction data, including the type, amount and/or description of the product or service purchased, delivery address, payment channel used, transaction amount, transaction date and time, and other transaction details;
    7. fill in payment data when Users carry out payment transaction activities through the Site, including but not limited to bank account data, credit cards, virtual accounts, instant payments, internet banking, retail outlets; and/or
    8. fill in detailed data regarding delivery address (for Buyers), pickup address and store location (for Sellers), including but not limited to full address data, location coordinates in the form of longitude latitude, telephone number, and name listed when storing data on Sobatinfo.
    9. use features on the Site that require permission to access relevant data stored on the User’s device.
  2. Data recorded when the User uses the Site, 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 time of each User activity in connection with the use of the Site, including registration, login and transaction time;
    3. usage data or User preferences, including User interactions in using the Site, saved options, and selected settings. The data is obtained using cookies, pixel tags and similar technologies that create and maintain a unique identifier;
    4. device data, including the type of device used to access the Site, including hardware model, operating system and version, software, IMEI number, file name and version, language choice, unique device identifier, advertising identifier, serial number, device movement information, and/or cellular network information; and/or
    5. log data, including records on servers that receive data such as device IP addresses, date and time of access, application features or pages viewed, application work processes and other system activity, type of browser (browser), and/or sites or services third parties that the User uses before interacting with the Site.
  3. Data obtained from other sources, including but not limited to:
    1. data in the form of geo-location (GPS) from Sobatinfo’s business partners who help Sobatinfo in developing and presenting services on the Site to Users, including payment service provider partners, logistics or couriers, site infrastructure, and other partners.
    2. data in the form of e-mail, telephone number, name, gender, and/or date of birth from Sobatinfo business partners where Users create or access Sobatinfo accounts, such as social media services, or sites/applications that use Sobatinfo’s application programming interface (API) or those used by Sobatinfo ;
    3. data from financial service providers, including but not limited to credit rating agencies or bureaus or Credit Information Management Institutions (LPIP);
    4. data from financial service providers (if the User uses specific features such as applying for a loan through the Sobatinfo Site/Application); and/or
    5. data in the form of email from marketing service providers.

Sobatinfo can combine data obtained from these sources with other data it has.

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B. Use of Personal Data

Sobatinfo can use Personal Data obtained and collected from Users as mentioned in the previous section for the following matters:

  1. Process all forms of requests, activities and transactions made by Users through the Site, including for the purpose of sending products to Users.
  2. Provision of features to provide, realize, maintain and improve our products and services, including:
    1. offer, obtain, provide, or facilitate marketplace services such as homepages, searches, searches, TopAds ads, product recommendations, Sobatinfo Feed, insurance, financing, loans, or other products through the Site;
    2. enable features to personalize User Sobatinfo accounts, such as Shopping Cart, Wishlist and Favorite Stores; and/or
    3. carry out internal activities necessary to provide services on the Sobatinfo website/application, such as solving software problems, bugs, operational problems, conducting data analysis, testing, and research, and to monitor and analyze trends in usage and activity.
  3. Assist Users when communicating with Sobatinfo Customer Service, including to:
    1. examine and solve User problems;
    2. direct User questions to the right customer service officers to solve problems; 
    3. oversee and improve Sobatinfo’s customer service responses;
    4. contact Users via email, letter, telephone, fax and other communication methods, including but not limited to assisting and/or completing the transaction process or problem solving process, as well as delivering news or other notifications regarding the protection of User Personal Data by Sobatinfo, including failure to protect User’s Personal Data;
    5. use information obtained from Users for the purpose of research, analysis, product development and testing in order to improve the security of services on the Site, as well as develop new features and products; And
    6. inform Users regarding products, services, promotions, studies, surveys, news, the latest developments, events and other information, both through the Site and through other media. Sobatinfo may also use this information to promote and process contests and sweepstakes, provide prizes, and present relevant advertisements and content about Sobatinfo’s services and its business partners.
  4. Monitoring or investigating suspicious transactions or transactions that are indicated to contain elements of fraud or violations of the Terms and Conditions or applicable legal provisions, as well as taking the necessary actions as a follow-up to the results of monitoring or investigation of these transactions .
  5. Under certain circumstances, Sobatinfo may need to use or disclose User 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 the User and Sobatinfo, or suspected criminal acts such as fraud. or data theft.
  6. Fulfillment of the requirements and obligations of the applicable laws and regulations in relation to taxation interests in Indonesia.
  7. Facilitate merger transactions, sales of company assets, consolidation or restructuring, financing or acquisitions involving Sobatinfo.

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C. Disclosure of User Personal Data

  1. Sobatinfo is committed to maintaining the confidentiality of User Personal Data under Sobatinfo’s control and guarantees that there is no disclosure, sale, transfer, distribution and/or borrowing of User Personal Data to other third parties, without the consent of the User, except in the following cases:
    1. it is necessary to disclose User Personal Data to partners or other third parties who assist Sobatinfo in presenting available services or services that will be available in the future on the Site and process all forms of User activity on the Site, including processing transactions, verifying payments, promotions, and shipping product.
    2. Sobatinfo can provide User Personal Data to business partners in accordance with User agreement to use business partner services, including applications or other sites that have integrated APIs or services with each other, or business partners with which Sobatinfo has collaborated to organize promotions, competitions or special services available on the Site, such as the Trade-In or Direct Sale program organized by Sobatinfo. 
    3. Sobatinfo can provide User Personal Data to third parties who use and integrate the public API provided by Sobatinfo (including but not limited to Sobatinfo’s business partner service providers) with applications or sites it operates for the purpose of completing transactions between Buyers and Sellers on the Site or for purposes of use. Other Personal Data mentioned in Part B of this Privacy Policy. 
    4. communication between Sobatinfo’s business partners (such as logistics, payment providers, feature providers or other service facilities) and Users is needed in terms of solving problems and other matters.
    5. Sobatinfo can provide User Personal Data to vendors, consultants, marketing partners, firms/research institutions, or similar service providers in the context of marketing activities carried out by third parties, improving and maintaining the quality of Sobatinfo’s services, and other publication activities.
    6. Users contact Sobatinfo through public media such as blogs, social media, and certain features on the Site, where the communication between the User and Sobatinfo can be seen and known by the general public.
    7. Sobatinfo may share User Personal Data with its subsidiaries and affiliates to help provide services or perform data processing for and on behalf of Sobatinfo.
    8. Sobatinfo can disclose and/or provide User’s Personal Data to interested parties in the context of carrying out a User’s credit worthiness analysis. 
    9. Sobatinfo discloses User Personal Data in an effort to comply with legal obligations and/or there is a valid request from law enforcement officials or an authorized state administration agency.
  2. In connection with the disclosure of User Personal Data as described above, Sobatinfo will/may need to disclose User Personal Data to third party service providers, agents and/or affiliates or companies related to Sobatinfo, and/or other third parties located outside the territory of Indonesia. Nonetheless, third party service providers, agents and/or affiliates or related companies and/or other third parties will only manage and/or utilize User Personal Data in connection with one or more purposes as set out in this Privacy Policy and in accordance with regulatory provisions. applicable laws.

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D. Cookies

  1. Cookies are small files that will automatically take place on a User’s device that performs the function of storing User preferences and configurations while visiting a site.
  2. These cookies are not intended for use when accessing other data that the User has on the User’s computer device, other than what the User has agreed to submit.
  3. although the User’s computer device will automatically receive cookies, the User can make the choice to make modifications through the User’s browser settings, namely by choosing to refuse cookies (this option can hinder the optimal availability of Sobatinfo services when the User accesses the Site).
  4. Sobatinfo uses the Google Analytics Demographics and Interest feature. The data that Sobatinfo obtains from these features, such as age, gender, User interests and other information that can identify Users, will be used by Sobatinfo to develop features, facilities and/or content contained on the Sobatinfo Site. If the User does not want his data to be tracked by Google Analytics, the User can use the Google Analytics Opt-Out Browser Add-On.
  5. Sobatinfo can use features provided by third parties in order to improve Sobatinfo services and content, including among other things, evaluating, customizing, and serving advertisements to each User based on interest or visit history. If the User does not want the ad to be displayed based on these adjustments, then the User can set it through the browser.

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E. User Choice and Transparency

  1. Mobile devices in general (iOS and Android) have settings so that the Sobatinfo application cannot access certain data without the consent of the User. iOS devices will provide notifications to Users when the Sobatinfo application first requests access to the data, while Android devices will provide notifications to Users when the Sobatinfo application is loaded for the first time. By using the application and providing access to the application, the User is deemed to have given his consent to the collection and use of User’s Personal Data on his device.
  2. After a sale and purchase transaction via the Site is successful, both the Seller and the Buyer (as defined in the Terms and Conditions) have the opportunity to provide ratings and reviews of each other. This information may be publicly viewable with the User’s consent.
  3. Users can access and change information in the form of email addresses, telephone numbers, dates of birth, gender, address lists, payment methods and bank accounts through the settings feature on the Site.
  4. Users can opt-out from information or notifications in the form of bulletins, reviews, product discussions, private messages, or private messages from Admins sent by Sobatinfo through the settings feature on the Site. Sobatinfo can still send messages or emails in the form of transaction information or information related to User accounts.
  5. As long as it does not conflict with the provisions of the applicable laws and regulations, Users can contact Sobatinfo to withdraw approval for the acquisition, collection, storage, management and use of User data. If this happens, the User understands the consequences that the User cannot use Site services or other Sobatinfo services.

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F. Security, Storage and Deletion of User Personal Data

  1. Sobatinfo protects each User’s Personal Data stored in its system, and protects this data from unauthorized access, use, modification, retrieval and/or disclosure by using a number of security measures and procedures, including User passwords and OTP (One Time Password) codes.
  2. User Personal Data may also be stored or processed outside the country by parties working for Sobatinfo in other countries, or by third party service providers, vendors, suppliers, partners, contractors or Sobatinfo affiliates. In this case, Sobatinfo will ensure that the Personal Data remains protected in accordance with Sobatinfo’s commitments in this Privacy Policy.
  3. Even though Sobatinfo has used its best efforts to secure and protect User Personal Data, it should be noted that sending data via the Internet is never completely secure. Thus, Sobatinfo cannot guarantee 100% the security of data provided or sent to Sobatinfo by Users and the provision of information by Users is a risk borne by the User himself.
  4. Sobatinfo will delete and/or anonymize User Personal Data under Sobatinfo’s control if (i) User Personal Data is no longer needed to fulfill the purpose of its collection; and (ii) storage is no longer required for the purpose of compliance with the applicable laws and regulations. 
  5. Please note that there is still a possibility that some of the User’s Personal Data is stored by other parties, including authorized state administration agencies. In the event that we share User Personal Data with authorized state administration agencies and/or other agencies that may be appointed by the competent government or have cooperation with Sobatinfo, Users agree and acknowledge that storage of User Personal Data by these agencies will follow their respective data storage policies. each of these agencies. 

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G. Access and Correction of User Personal Data or Withdrawal of Consent

  1. Sobatinfo takes reasonable steps to ensure that User Personal Data is processed accurately and completely. However, it is important for the User to notify Sobatinfo in a timely manner about any changes to the User’s Personal Data or if there is an error in the User’s Personal Data which is under the control of Sobatinfo.
  2. Users have the right to access or correct User Personal Data under Sobatinfo’s control through Sobatinfo’s customer service provided in this Privacy Policy. However, the application will only be processed by Sobatinfo if the User has submitted sufficient proof of identity to access or correct the data. Sobatinfo has the right to refuse requests to access, or to correct, some or all of the User’s Personal Data that Sobatinfo owns or controls if permitted or required based on applicable laws. This includes situations where the Personal Data may contain references to other people or where requests for access or requests for corrections are for reasons that Sobatinfo deems irrelevant, not serious,
  3. Sobatinfo may charge Users with administration fees to handle User requests to access or correct User Personal Data. 
  4. Users can withdraw the consent that the User has provided regarding the processing of User’s Personal Data which is under the control of Sobatinfo by sending the request through Sobatinfo’s customer service listed in this Privacy Policy. Sobatinfo will process the User’s request within a reasonable period of time since the request for withdrawing the consent was submitted, and subsequently will not process User’s Personal Data in accordance with the User’s initial request, unless required by applicable laws and regulations. In the event of a withdrawal of consent, Sobatinfo may not be able to carry out its obligations based on any agreement between the User and Sobatinfo. In connection with that matter, 

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H. Complaints regarding User Data Protection

  1. If the User has concerns about Sobatinfo’s handling or treatment of User’s Personal Data or if the User believes that his privacy has been violated, the User can contact Sobatinfo through Sobatinfo’s customer service or to the Sobatinfo contact listed in this Privacy Policy by explaining the identity and nature of the User’s complaint.
  2. Sobatinfo will investigate User complaints and endeavor to respond to these complaints within a reasonable time after receiving complaints submitted by Users.

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I. Contact Us

In the event that the User has questions, comments, complaints or claims regarding this Privacy Policy or the User wishes to gain access and/or make corrections to his Personal Data, please contact Sobatinfo’s customer service via the page .

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J. Retention, Requests for Data Subjects and Deletion of Information

  1. Sobatinfo will store information as long as the User’s account is active in accordance with the provisions of the applicable legal regulations in Indonesia.
  2. Users have the right to submit data subject requests to Sobatinfo, which can be seen in full HERE .
  3. Users can request the deletion of User information through the Sobatinfo and Sobatinfo mobile applications which will be opened periodically which can be seen in full HERE . 
  4. Sobatinfo will process data subject requests in accordance with the provisions of the applicable legal regulations in Indonesia. 

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K. Privacy Policy Update

Sobatinfo may change or update this Privacy Policy at any time as part of compliance with laws and regulations and internal company policies. Sobatinfo will notify Users of any changes and/or updates to this Privacy Policy. 

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