PRIVACY NOTICE (FOR CUSTOMERS)
PERSONAL DATA PROTECTION NOTICE IN LINE WITH REGULATION OF PERSONAL DATA PROTECTION IN INDONESIA
We, PT. Future Mobility Solutions (hereinafter referred to as “PTFMS”, “we”, “us”, “our”, “TREVO” and other similar expressions), value and respect the privacy rights of all our customers across all aspects of our business and we strive to protect your Personal Data in compliance with the laws of Indonesia.
PTFMS will only collect and use your Personal Data in accordance with the Regulation of Ministry of Communication and Information number 20 of 2016 on Personal Data Protection in Electronic System (and any other such laws that may be enacted from time to time) (hereinafter referred to as “Regulation”), with this Privacy Notice and such other term(s) in the agreement(s) that you may contract with us or have contracted with us.
We highly encourage that you carefully read this Privacy Notice to allow you to understand how we collect, use, handle, retain, disclose, and protect your Personal Data. Succinctly, this Privacy Notice explains:
1. The type of Personal Data that we collect;
2. How we collect your Personal Data;
3. The purposes for which we collect your Personal Data;
4. How we use your Personal Data;
5. The parties that we may disclose your Personal Data to; and
6. The choices that we offer for you to access and update your Personal Data.
Kindly take note that unless stated otherwise, the words used herein shall have the same meaning and definition as in Regulationand the TREVO Terms Of Service.
The Personal Data That We Collect
In order to provide you with our service(s), deal with your inquiry(ies), open and operate an account with us, and/or to inform you of current and upcoming promotion(s), we need to collect and use your Personal Data or the Personal Data of a third person. In the event that we are not provided with all the Personal Data that we request, we may not be able to provide you with our service(s) or continue to provide you with our service(s).
The extent and type of Personal Data that we collect from you depends on our service(s) that you subscribe to and/or the purpose of the collection of the Personal Data. The Personal Data that we collect may include, but not limited to, your name, Identity Card Number, nationality, passport number, address, email address, mobile phone number, date of birth, gender, race, photograph, video, employment status, employer’s details, parking habits and lifestyle choices, motor vehicle registration number, credit card details, and/or debit card details. If you are a company, we may collect such data including, but not limited to, your company registration number, your phone and/or fax number, your business and/or registered address, and/or your employee’s Personal Data. Companies shall obtain the consent of the employees before providing us with the employees Personal Data.
How We Collect Your Personal Data
We will collect your Personal Data via a completed TREVO registration form that you have provided to us (whether through the Application, the Website, or a physical form), or any other similar forms and/or any information about you that has been or may be collected, stored, used and processed by TREVO from time to time and includes sensitive Personal Data such as data relating to health, religious or other similar beliefs.
The provision of your Personal Data is voluntary. However, if you do not provide TREVO your Personal Data, your request for the Application may be incomplete and TREVO will not be able to process your Personal Data for the Purposes outlined below and may cause TREVO to be unable to allow you to use TREVO service.
We may also collect your data from third party related application(s) or software(s) for the purpose of providing you with our services or related services. We may also collect your Personal Data from your employer where the services we provide are related to your employer-employee relationship and we may collect your Personal Data from your employees. In addition to the above, we may also collect your Personal Data from any third-party that you have authorized to disclose your Personal Data to us.
The Purpose of The Collection of Your Personal Data
We collect your Personal Data for the following purposes:
1. to identify users of our service, potential users and their representatives;
2. to provide our services;
3. to provide related services;
4. to manage and maintain your account with us;
5. for administration purpose(s);
6. to develop and/or implement initiatives to improve our services;
7. to seek your opinions or comments about our services;
8. to inform you about promotions, offers and/or other benefits (including third party benefits) that may become available;
9. to carry out our management, administrative, quality assurance and complaint handling activities in a professional and efficient manner;
10. conduct consumer and market research;
11. to follow up or pursue any queries you make;
12. for any other purpose(s) related thereto; and
13. for any purpose(s) required or permitted by any law, regulations, guidelines, and/or relevant regulatory authorities.
Use and Disclosure of Personal Data
We shall use and disclose your Personal Data for such purpose(s) that the Personal Data was collected, as indicated above and for any other secondary purpose(s).
We shall disclose, where necessary, your Personal Data to our related entities, landlord(s), service providers, and/or contractors, who assists us in providing and/or supplying our product(s) and service(s).
Notwithstanding the above, we may be required, as a result of our contractual obligation(s) to you or to any other third-party, to disclose your Personal Data to the landlords of a particular car parking facility that we manage and operate, and to our auditors who shall conduct audits of our business and services.
Except where indicated above, we will not use and/or disclose your Personal Data unless:
1. we have obtained the consent from the individual concerned;
2. the third-party we disclose the Personal Data to are our agent, service provider and/or contractor, in which case we will require them to only use and disclose the Personal Data only for the purpose for which it was provided to them;
3. the third-party is a person involved in a dealing or proposed dealing (including but not limited to a sale) of all or part of our assets and/or business;
4. the third-party is a credit reporting agency, your creditor, banker, financier, and/or credit provider; and
5. the disclosure is permitted, required and/or authorized by or under law.
In addition to the above, we may use your Personal Data to advise and inform you of new product(s), service(s) and/or marketing initiative that we think may be of interest to you. This may include, but not limited to, product and/or service offerings, newsletters and general information about us and/or third-parties.
If you prefer not to receive information about such product(s) and service(s), you can contact our Customer Service Officer and request to be removed from the relevant circulation list.
We would like to highlight to you that your act of unsubscribing will not end the transmission of service-related emails from us, such as administrative email alerts in relation to your account settings except where you have terminated your account with us.
You are more than welcome to request to have access to your data within our storage at any time. If you wish to do so, you may at any time, log in into your TREVO application account and view your data within our storage.
In the event that such data of yours is not made available to you via your online account or that you are unable to access your Personal Data, kindly contact our Customer Service Officer. Our Customer Service Officer shall do their best to grant you access where possible within twenty-one (21) days from when our Customer Service Officer receives your request. In the event that we are unable to comply with your request within the aforementioned twenty-one (21) days, we shall try our best to comply within thirty-five (35) days from when our Customer Service Officer receives your request.
1. the identity of the data subject is unidentifiable from the information given;
2. the access impacts on the privacy of others;
3. the request for access is frivolous or vexatious;
4. the cost incurred is far too great;
5. there are confidential commercial information that may be disclosed in the process;
6. the Personal Data is with another data user and such data user are unable to comply;
7. there are existing or anticipated legal proceedings; or
8. such access can be denied under law or by a law enforcement agency
we may not be able to provide you with access to the Personal Data we hold about you. In the event that we deny and/or are unable to comply with your request for access, we will inform you of the reason(s) of our denial and/or inability to comply.
Please note that in processing your request, we may charge you a reasonable fee as prescribed under the Regulation or its amendment from time to time to cover any cost incurred by us.
Quality & Correction
We strive to ensure that your Personal Data with us are accurate, complete and up-to-date at all times. If at any point in time you believe that any of the Personal Data of yours that we hold is inaccurate, incomplete or not up-to-date, you should immediately inform us with the correct, complete and accurate data. We will use all reasonable efforts to correct the data within twenty-one (21) days from when our Customer Service Officer receives your request for correction. In the event that we are unable to make such correction within the aforementioned twenty-one (21) days, we will inform you of our inability to make such correction within reasonable time as well as the reason as to why we are unable to do so. We shall, however, try out best to comply within thirty-five (35) days from when our Customer Service Officer receives your request for data correction.
Alternatively, you may log into your TREVO application account with us and update your details there as this method of correction would be much more fast and convenient for you. In the event that you are unable to correct your details there or such detail is locked from being altered, kindly contact our Customer Service Officer and our Customer Service Officer shall do their best to make the necessary amendment(s) for you.
How We Store Your Personal Data
As we strive to protect your Personal Data, we limit the personnel that can access your data and the amount of data accessible by them. Only personnel that specifically requires your Personal Data may access it to carry out their business responsibilities. Our employees are at all times obliged to respect the confidentiality of any Personal Data held by us.
We take reasonable steps to keep your Personal Data secure and protect it from loss, misuse, or unauthorized alteration. Any of the Personal Data you electronically provide to us are stored on secure servers. We also maintain a reasonable physical security procedure to manage and protect the use and storage of records containing Personal Data.
WEBSITE, APPLICATION & COOKIES
In order to ensure that we meet the needs and wants of our website and application users in addition to further develop our online services, we may collect aggregated information by using cookies or similar electronic tools.
Changes to Our Privacy Notice
We may update or change this Privacy Notice at any time, from time to time as and when we find it necessary to do so. When we do so, we will publish the updated Privacy Notice on our website which shall supersede the previous version of the Privacy Notice. The updated Privacy Notice will apply between us whether or not we have given you specific notice of any change.
We are committed to constantly improve our procedures to ensure that Personal Data that we process are kept secured and treated appropriately. If you feel that we have failed to deal with your Personal Data in accordance with this Privacy Notice, please speak to us so that we have an opportunity to resolve the issue to your satisfaction.
We will log your complaint and our Customer Service Officer will:
1. listen to your concerns and grievances;
2. discuss with you the ways in which we can remedy the situation; and
3. put in place an action plan to resolve your complaint and improve our Personal Data handling procedures if appropriate.
Disclosure to Overseas Recipients
We will not disclose your Personal Data to recipients located outside of Indonesia except where we are required to do so by our parent company and for administrative purposes.
This Privacy Notice is prepared in English and Bahasa Indonesia. In the event of any discrepancies between the English and Bahasa Indonesia versions of this Privacy Notice, the English version shall prevail.
If you wish to access any of your Personal Data that we hold about you, or have a query about this Privacy Notice, please contact our Customer Service Officer email email@example.com