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Indonesia

Objective

ShopKey/ShopKey Biz’s privacy policy document explains the associations related to the collection, usage,  disclosure and transfer of the Merchant’s (hereby referred to as User) information by ShopKey/ShopKey Biz or  its affiliates, such as its parent company, namely PT. GAMECHANGE SOLUTIONS INDONESIA  or a Holding Company located in Singapore, namely GAMECHANGE SOLUTIONS INDONESIA  PTE. or other subsidiaries. ShopKey/ShopKey Biz is available on Google Play , Apple  App Store, other similar Marketplace Apps, platforms, and services; and is not limited to  collection of credit/payment data, fees/balance information through websites and applications,  and information about other online or internet-connected devices (collectively, the “ShopKey/ShopKey Biz  Application Services”). This Policy is a part of the Terms of Use for ShopKey/ShopKey Biz Application Services. The definitions in  capital letters that have been used in this Privacy Policy, however not interpreted, have the  same meaning as related to them in the Terms of Use. Users are required to understand this  Policy in relation to the Terms of Use. The following must be considered and understood to make it easier for users to run business  online. The users are required to:
  1. Describe the products sold in detail along with specifics on how to use said products, their quantity and composition.
  2. Include detailed, clear and competitive prices along with the method of payment attached, and send a downloadable link to serve as proof of the transaction.
  3. Understand that if a transaction is made outside the ShopKey/ShopKey Bizapplication then it is not  the responsibility of ShopKey/ShopKey Biz and its affiliates.
  4. Maintain timely and clear coordination and communication with customers during the order process and while responding to user requests, so that there are no

ShopKey/ShopKey Biz Scope 

ShopKey application helps Users to: (i) Create an online store; (ii) Create and maintain catalogues that can be shared with respective customers through  various platforms; (iii) Issue a payment link that can be sent to the respective customer who can then use it to  make a payment of a certain amount to the User as a settlement towards the products and  services availed; (collectively, the “Services”). Please understand that ‘Service’ includes a list of current and prospective services that are subject  to change, (improve, update, expand and increase or decrease in number) at our sole discretion. This Policy is subject to change; therefore, Users are advised to refer to the policy periodically.  By accessing the Site, Application, or using the ShopKey/ShopKey Biz Application Service, you hereby  consent to us collecting, storing and using the personal information you provide for all the  services we offer. We take the privacy of ShopKey/ShopKey Biz Application Service users very seriously and we are highly  committed to protecting to protecting it well with the best of security measures. The Information  we require to collect from the User is as follows: (a) personal information provided by the User during registration and/or the usage of the  application (b) information that is automatically tracked when using a mobile device running the ShopKey/ShopKey Biz  Application Service. By accessing the Site, Application, or using the ShopKey/ShopKey Biz Application Service, you hereby agree to  the Policy provided and consent to us collecting, storing and using the personal information you  provide for all the services we offer. If you do not agree with the provisions contained in this Policy,  you are hereby advised to refrain from using/taking advantage of the ShopKey/ShopKey Biz Application Service

User Information 

In order to avail the benefits of the Services on the ShopKey/ShopKey Biz Application, Users are required  to provide personal information for the registration process as follows: (a) Name of owner/seller, (b) Name of the online shop along with the chosen web domain that must be available (c) e-Mail address, (c) Phone number of the shop (d) Merchant information (e) Mobile number of the User (f) Merchant’s address (g)) KYC (Know-Your-Customer) details and other required information. The information  provided by Users enables us to provide the Services with the most user-friendly experience  possible and to improve the ShopKey/ShopKey Biz Application Services.

Right to Access Information 

After the Application is downloaded, the User is asked to provide access to their contact list  in the mobile device used for downloading the application, thereby enabling the User to share  transaction details such as payments/credits with their customers and other services from  the user to their customers. In an effort to improve the Service, we may collect valid and vital information from Users via  the ShopKey/ShopKey Biz Application. We ensure that we do not share this data with other parties except  in accordance with the provisions of this Policy. The application can access an inventory of applications that Users connect to and use this  data as personal data or sensitive data subject to this Policy, secure delivery process, and User  disclosure requirements. We may use User’s email address and phone number without further consent for marketing  and administrative purposes (such as notifying you of changes, for customer service purposes,  providing information regarding updates to ShopKey/ShopKey Biz Application Services, finance, etc.) Any information you provide will not be considered personal information if it is freely  available and/or accessible in the public domain or is not considered personal information  under applicable law. Furthermore, reviews, comments, messages, suggestions and criticisms  uploaded / communicated / submitted by Users in public sections on the Site or Apps (such as the App Store or Play Store) become content that will be published and are not considered  personal information subject to this Policy. We may use Information to provide Services, update, protect and improve ShopKey/ShopKey Biz  Application Services, and to develop new Services. If you object to submitting Information on the ShopKey/ShopKey Biz Application, we cannot provide you  with services on the ShopKey/ShopKey Biz Application. We will make every effort to inform you of the  same in a timely manner. However, we are entitled to deny you of certain or all services on the  basis of non-provision of required information from your end. When you register with the ShopKey/ShopKey Biz Application Services, we reserve the right (at our  discretion) to contact you to update your Information.

Information Detected by ShopKey/ShopKey Biz Application 

Demographic Information 

We may look at demographic sources and other information to provide you with targeted  promotion data. We use Google Analytics to track User behaviour on the Site.

Cookies 

In order to improve the responsiveness of the Site for our Users, we may use “cookies” or  similar electronic tools that collect information to assign a random and unique number as a  User Identification (User ID) for each visitor to understand the individual interests of the User  who uses a specific device. By frequently visiting the Application/Site, you consent to the use  of cookies and similar technologies for the purposes we describe in this Policy. If you choose  not to accept cookies, then it is advised for you to stop using the Service, or check your third  party browsing and cookie settings. Cookies and other technologies are used to analyze and  optimize our website and for marketing purposes. Our partners may also assign their own  cookies to your search engine (browser), which is a process we have no control over.

Log File Information 

Our servers automatically collect restricted Information about your device’s connection to  the internet, including your IP address, when you visit our Site or use the Application. We  automatically receive and record Information from your Application and/or browser including  but not limited to your IP address, your device or computer name, and your operating system.  We may also collect log Information from your device, including but not limited to your  location, IP address, your device name, device serial number or unique identification number  (e.g. IDFA on your iOS device, Android ID or ADID on your Android device), your device’s  operating system, search engine (browser) type and version, CPU speed and connection  speed, etc.

Promotion Server 

These servers may include links to other websites such as Blogs, advertisements, sponsored  content, vendor services, social networks, etc. Such websites are governed by privacy policies  of their respective companies, which are beyond our control. Once you log out of our server (you can find out where you are by checking the URL in the  location bar of your browser), the use of any information you provide is governed by the  privacy policies of the ShopKey/ShopKey Biz operator that runs the site you visit and we make no  representations or warranties regarding how your information is stored or used on a third party server. If you cannot find the privacy policy of any one of these sites via the link on the website’s  homepage, you should contact the website directly for more information.

Updating Personal Information 

When the User has accessed the Application, we make every effort to provide the User, as  requested by the User, with access to their Information and further ensure that all personal  and sensitive Information or other Information which is found to be inaccurate or lacking is  edited of requested for correction, subject to any requirement that states Personal  Information or sensitive data or any such Information to be retained by law or for legitimate  business purposes. We request the individual Users to identify themselves and the Information requested to be  assessed, corrected or deleted prior to processing requests. We reserve the right to refuse to  process requests that are repeated or systematic in an unreasonable manner, that require  further disproportionate technical efforts, that jeopardize the privacy of other people, that  becomes highly impractical (for example, requests for Information residing on backup tapes),  or requests that don not require access. In any case, where we provide access to Information and remedies, we perform these services  free of charge, unless doing so requires a disproportionate amount of effort. Given the way  we maintain certain services, once you delete Information, residual copies may take some  time before they are deleted from our active servers and it is possible for them to remain in  the backup system.

Sharing information 

The information collected may be shared with our affiliates, our group companies (for our  internal business purposes and/or administrative purposes and/or general company  operations), and also with any third-party service providers including marketing partners. The  User hereby agrees to this. We will take appropriate steps to ensure that these third-party service providers are obligated  to protect your personal information and are also subject to confidentiality/non-disclosure  obligations and comply with applicable data protection laws. These entities, with whom we share information, may market to you as a result of such  sharing, unless you explicitly choose not to be shared. Regarding the data being shared, please  convey your preferences by sending us an electronic mail (email) via help@goshopkey.com. The User hereby agrees that we may be granted access to the User’s short messages (SMS),  contacts on the mobile device, location and device information and we request for all the  data necessary for KYC (Know-Your-Customer) requirements to enable us to check User’s  eligibility for certain products/services including, but not limited to, credit and product  payments and so on. This is necessary to enhance your experience and provide you with  access to the services we, our affiliates, or other third party service providers (including  lenders) offer. In continuation, the User also agrees to share Information (including sensitive personal  information) when requested or required by law or court or government agency or authority  for the purpose of identity verification, or for prevention, detection, and investigation of  cyber violations, or for any other legal cases and violations. This disclosure is made in good  faith and with the belief that such disclosure is reasonably necessary to enforce the Terms of  Use or to comply with applicable laws and regulations. None of the User’s personal information such as name, telephone number, electronic mail  (email) address, expense data, card details, etc. will be shared with other Users and/or third  parties unless it has been specifically approved by the respective User. We may, however,  provide information related to credit records, User spending patterns and User data that we  track in the form of overall statistics for data such as overall application usage by date, time,  balance, etc. in the Application/Site, to our partners. By using the ShopKey/ShopKey Biz Application Service and providing information to us, the User has  consented to the disclosure, transfer, storage and processing of personal information  (including sensitive personal information) by us in Indonesia and/or other countries of its  affiliates, group companies and third parties. Although our primary motive is to protect the  disclosure of Users’ personal information, except in accordance with the provisions of this  Policy, Users may note that the country in which their Information may be stored, may not  have the same regulations regarding data protection as the country in which they are located. Information that you have provided as part of the registration process on the ShopKey/ShopKey Biz  Application, such as your name and location, can be accessed and promoted via search  engines, crawlers, and other similar codes. These matters are beyond our responsibility and  we hereby disclaim our inability to provide completely assurance that your Information will  not be disclosed to third parties. In continuation to the above, you have agreed that we may keep your personal information  confidential so that you cannot be identified individually, and we reserve the right to share  this de-identified information and some comprehensive findings (including findings of  personal information) with advertisers, sponsors, investors, strategic partners, and such to  help the business grow.

Data collection 

All ShopKey/ShopKey Biz Application Services activities are currently provided and regulated by PT.  Gamechange Solutions Indonesia and PT Gamechange Solutions Indonesia is entirely  responsible for the collection, storage and processing of personal information obtained from  the Users.

Data Update 

ShopKey/ShopKey Biz may change the Policy from time to time to implement necessary changes in  technology. In such cases, ShopKey/ShopKey Biz reserves the right to change, at any time, the terms of this  Policy or the Terms of Use. Any changes we make will take effect immediately upon  notification, which we may provide, on publishing the new policy, on the Site. Your continued  usage of the ShopKey/ShopKey Biz Application Services after said notification has been provided, will be  deemed as your acceptance of the changes. We will also make reasonable efforts to notify  you by electronic mail (email). In any case, you are advised to periodically review this Policy  on the Site to ensure that you are aware of the latest version.

Information Security 

ShopKey/ShopKey Biz implements strict security policy measures to protect against unauthorized access  or alteration, disclosure or destruction of data including intentional or unintentional  manipulation, and loss/deletion of account access by unauthorized parties. This includes  internal reviews of our data collection, storage, and processing activities, along with security  measures which include appropriate encryption, as well as physical security standards, to  protect against unauthorized access to systems where we store personal data. All Information  collected on the Application is stored securely in a controlled database. Access to the server  is password protected and strictly restricted. Our security measures are reviewed and updated regularly to reflect technological  developments. Regardless of where your personal information is transferred to or stored, we  take all reasonably necessary steps to ensure that all personal information is stored securely.  However, please understand that no data transmission over the internet or other public  networks can be secured with 100% guarantee. We strive to ensure compliance with applicable data protection legalities to provide  protection and safeguard the privacy and personal information of Users. We have physical,  electronic, and procedural safeguards that comply with applicable laws, in certain  jurisdictions, to protect Users’ Personal Information. By accepting the terms of this Policy, you  agree that the standards and practices we apply are reasonable and adequate to protect your  personal information. In case of any breach of security, confidentiality or integrity of your Personal Information  stored electronically and unencrypted to you by electronic mail (email) or other appropriate  means, we will contact you at the earliest, without unreasonable delay provided it is  consistent with the legitimate needs of law enforcement. We will take all necessary actions  to determine the scope of the breach and restore reasonable data system integrity.

ShopKey/ShopKey Biz Information Storage 

At predetermined intervals, we are entitled to take backups of your data from the ShopKey/ShopKey Biz  App into our highly secured cloud database. This is intended to allow Users to  access/withdraw their data in case their device’s data cannot be used, or if the connected  device is lost, or when the User changes to a new device. We also use these backups to  provide insight and information regarding spending per-month in relation to shopping behavior, customer spending patterns, and other User related data in the form of  comprehensive and anonymous statistics (for example, User spending by category, date,  time, bank balance, etc.) We will retain User Information in our records for the entire duration of the time when we  potentially offer the ShopKey/ShopKey Biz Application Services to Users. After a period of time, during  which the ShopKey/ShopKey Biz Application Services are no longer relevant to the User, we will delete all  Information relating to that particular User from our records.

Expiration of Approval 

Users have the right to withdraw consent, but it must be noted that withdrawal of consent is  not retroactive. If you wish to have us delete the personal information provided by you,  please contact us at help@goshopkey.com and we will respond to you promptly. Please note  that ShopKey/ShopKey Biz is not responsible for downgrading, removing, or modifying any of your public  activities or submissions as a result of your public activities. Please note that withdrawal of  consent does not affect our right to collect, use and disclose personal information where  collection, usage and disclosure without consent is permitted or required under applicable  law.

Dispute 

For any personal information provided by you, which was not specifically requested by us  during registration (mandatory or optional), we are not responsible for any loss, leakage or  disclosure related to that information. If you have any questions regarding this Policy or the  protection of your Information, please contact our data protection officer/help centre.

Inquiries / Complaint Handling 

Complaints, suggestions or criticisms, if any, regarding the processing of the information you  provide us, may be shared with us at help@goshopkey.com or sent as a written document  to the following address: 6 Raffles Quay, #11-07, Singapore 048580.

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