INTRODUCTION
This Privacy Policy or Privacy Notice (“Privacy Notice”) takes effect as of January 10, 2025.
PT Guardia Teknologi Indonesia, operating under the trade name Jubelio, is a company that provides the JUBELIO website services, located in South Jakarta, Indonesia. Jubelio provides you with retail management solutions to increase sales and work efficiency for your online and offline business. The following Privacy Notice explains how we, PT Guardia Teknologi Indonesia (hereinafter referred to as “Jubelio” or “We”), obtain, collect, store, control, use, process, analyze, modify, update, display, announce, transfer, disclose, and protect Personal Data (“Processing Personal Data” or conducting “Personal Data Processing”) about you.
This Privacy Notice applies to all Users of our services (including Jubelio Omnichannel and Jubelio Omnichannel Partners), the website (https://jubelio.com), features, services, and products (collectively referred to as “You”), except where regulated in a separate privacy notice.
This Privacy Notice is an integral and inseparable part of the Terms and Conditions of Use of Jubelio (“Terms of Use”). We recommend that you read this Privacy Notice along with the Terms and Conditions of our products/services as these documents may contain specific product or service information regarding how we process your Personal Data. The use of the Platform and any features and/or services operated by us (“Services”) constitutes your consent to the Terms of Use and this Privacy Notice. Therefore, you need to read this Privacy Notice carefully to ensure that you fully understand it before registering, accessing, and/or using our Platform (including any of its Services).
This Privacy Notice is provided to you in both English and Indonesian, and both versions will be binding on you and us. In case of any discrepancy between the Indonesian and English versions, the Indonesian version shall prevail.
The Privacy Notice also has the same meaning as the privacy policy mentioned in the Terms of Use and any Services on our Platform.
ACKNOWLEDGMENT AND CONSENT
By agreeing to this Privacy Notice, you acknowledge that you have read, understood, and agreed to all its terms. Specifically, you agree and consent to us processing your Personal Data in accordance with this Privacy Notice.
We require your Personal Data, among other things, to process transactions on the Platform. Therefore, you declare that the Personal Data submitted to us at the time of account registration or updates is accurate and up to date, and you are responsible for updating and informing us of any changes to your Personal Data. You release us from any claims, lawsuits, or demands due to transaction processing failures or the use of Services caused by inaccuracies in the Personal Data you provide.
Furthermore, you guarantee that all data provided in written or other forms to use our Platform is genuinely yours and not obtained from a third party’s personal information without lawful authorization. Any issues arising from the provision and accuracy of such data are your full responsibility.
If you provide us with Personal Data belonging to another individual (for example, a spouse, family member, friend, or another party), you declare and guarantee that you have obtained consent from that individual, and you hereby consent on their behalf to the Processing of their Personal Data by us. We may request proof of such consent from you at any time.
We will protect your Personal Data in accordance with this Privacy Notice. However, we are not responsible for data you disclose or share, whether intentionally or unintentionally. You are considered to have waived the confidentiality of your Personal Data through such disclosure.
If you are under 18 years old (a minor under legal protection) or fall into the category of a child or unmarried person under the applicable laws and regulations, you must review this Privacy Notice with your parent or guardian. Ensure that your parent or guardian understands and agrees to the terms in this Privacy Notice before you use our Platform and Services. If your Personal Data is disclosed to us, you hereby declare and guarantee that your parent or legal guardian has given consent for the processing of your Personal Data in accordance with the applicable laws and regulations. Your parent or guardian also agrees to be bound by this Privacy Notice and is responsible for all actions you take on our Platform.
You may withdraw your consent for any or all Processing of your Personal Data at any time by providing us with reasonable written notice using the contact details mentioned below. You must understand and acknowledge that after withdrawing your consent, you may no longer be able to use our services. The withdrawal of your consent may result in the termination of services, deletion of your account, or termination of your contractual relationship with us, with all rights and obligations arising from it remaining fully fulfilled. Once we receive your consent withdrawal, we will inform you of any potential consequences so that you can decide whether you still wish to proceed with the withdrawal.
PERSONAL DATA
“Personal Data” refers to any and all information, data, and/or details in any form that can be used to identify you, which you provide to us from time to time or that you include or submit, directly or indirectly, on, in, and/or through the Platform concerning your personal information.
Personal Data includes, but is not limited to, your full name, identification number (including the number stated in your passport, national identity document, or other government-issued identification), address, date of birth, tax identification number (NPWP), payment information, email, mobile phone number, and other data classified as Personal Data as stipulated by the applicable laws and regulations.
To avoid doubt, applicable laws and regulations mean all applicable laws, company statutes, legislation, regulations, regulatory policies, ordinances, protocols, industry codes, regulatory permits, or requirements from courts, tribunals, or any government authority, enforcement, judiciary, administrative, or supervisory bodies, which apply from time to time during the validity period of this Privacy Notice (“Applicable Laws and Regulations”). Additionally, any other data, including personal profiles and/or unique identifiers, that is linked or combined with Personal Data is also classified as Personal Data.
It should be noted that Personal Data in this context does not include any personal information that has been made publicly available.
PERSONAL DATA WE COLLECT
Personal Data collected when you use the Platform, receive, or provide Services includes:
- Data collected from you as a Platform user
You may provide us with Identity, Contact, Eligibility, Profile, Financial, and Payment Data, including in situations where such data is requested by us or required under the Applicable Laws and Regulations, when you interact with us directly or correspond with us via mail, email, or other means. - Data collected from third parties
We may also collect your Personal Data from third parties (including vendors, partners, government institutions, and/or other parties that provide services to us, collect Personal Data, and/or perform tasks on our behalf, or those who collaborate with us). In such cases, we will only collect your Personal Data for or in connection with purposes involving those third parties or our collaboration with them (depending on the situation). - Data about third parties that you provide to us
You may provide us with Personal Data related to other individuals (including Personal Data related to your spouse, family members, friends, or other individuals). In such cases, you must obtain the consent of those third-party individuals—refer to the “Acknowledgment and Consent” section above for more details.
USE OF THE PERSONAL DATA WE COLLECT
We may use the collected Personal Data for the following purposes or for other purposes permitted under the Applicable Laws and Regulations (“Purposes“):
- If you are a User, we may use your Personal Data:
- To identify and register you as a user and to administer, verify, deactivate, and/or manage your account and/or transactions on the Platform.
- To facilitate or enable any necessary verification as deemed appropriate by us, for example, before a service provider can provide services to you or before we register you as a user.
- To communicate with you and send you information regarding your use of the Platform.
- To enable sellers to process orders, create orders, delete orders, edit orders, display orders, export orders, print shipping labels, and coordinate order logistics with warehouse and courier services integrated by the seller.
- To enable sellers to collect buyer contact data and delete buyer contact data.
- To process your requests regarding your rights as a Personal Data subject in relation to the Services, including but not limited to access, correction, updating, and/or deletion/destruction of Personal Data, as well as contacting you regarding your request.
- To maintain, develop, test, improve, and personalize products and services on the Platform to meet your needs and preferences as a user.
- To process and respond to inquiries, requests, comments, and/or feedback received from you.
- We may also use Personal Data without consent, relying on legitimate interests or other grounds for Personal Data Processing as stipulated under the Applicable Laws and Regulations, for purposes such as i) Complying with applicable laws and regulations; ii) Investigating potential fraud or illegal activities; or iii) Protecting our brand, reputation, or ownership. Using your Personal Data when required, advised, recommended, expected, or requested by our legal counsel, local or foreign regulatory bodies, governments, or other authorities.
DISCLOSURE OF PERSONAL DATA WE COLLECT
We may disclose, grant access to, or share your Personal Data with other parties for the following purposes, as well as for other purposes permitted under the Applicable Laws and Regulations:
- If you are a Buyer, to enable Users or partners to provide services or process orders, including contacting you.
- If you are a User or partner, to enable Buyers to request or receive services from you.
- To respond to regulatory inquiries, questions, requests, investigations, rulings, reporting, and to comply with filing requirements as stipulated in the Applicable Laws and Regulations.
- If instructed, requested, required, or permitted by authorized government institutions, for purposes stated in official letters, policies, government regulations, or the Applicable Laws and Regulations.
- If there is any legal proceeding of any kind between you and us, or between you and another party, in connection with or related to the services, for the purpose of legal proceedings.
- In emergency situations related to your health or safety (whether you are a User or a Buyer) to handle such emergencies.
- In situations related to your health or public interest (whether you are a User or a Buyer), we may share your Personal Data with authorized government institutions and/or other institutions designated by the government or collaborating with us, for contact tracing, supporting government initiatives, policies, or programs, public health, and other reasonably necessary purposes.
- In relation to mergers, company asset sales, consolidations or restructurings, financing, or acquisitions of all or part of our business by or to another company, for the purpose of such transactions (even if the transaction is later not completed).
If there is Personal Data that does not need to be associated with you, we will take reasonable steps to remove its association with you as an individual before disclosing or sharing such data.
We will not sell or rent your Personal Data.
INTERNATIONAL DATA TRANSFER
Your Personal Data that we collect may be stored, transferred, or processed outside Indonesia by third-party service providers for one or more of the purposes mentioned in this Privacy Notice.
We will comply with all Applicable Laws and Regulations and use our best efforts to ensure that the country where the third-party service provider receiving the data is located has a level of Personal Data protection equal to or higher than Indonesia. Alternatively, we will ensure that the third party receiving your Personal Data has adequate and binding Personal Data protection standards or, at the very least, obtain your consent for the transfer of your Personal Data. You understand and consent to the transfer of your Personal Data outside Indonesia.
STORAGE OF PERSONAL DATA
Your Personal Data will only be stored as long as necessary to fulfill the purpose of its collection, during the retention period, or as required or permitted by the Applicable Laws and Regulations. We will cease storing Personal Data or remove its association with you as an individual as soon as it is determined that the purpose of collecting the Personal Data is no longer needed, upon your request for account deletion, and when retention is no longer required for business or legal purposes.
Jubelio will delete and/or anonymize User Personal Data under Jubelio’s control if (i) The User’s Personal Data is no longer necessary to fulfill the purpose of its collection; (ii) The retention period has expired; and (iii) Retention is no longer required for compliance with applicable laws and regulations.
Please note that there may still be instances where some of your Personal Data is stored or controlled by other parties, including government institutions, in certain ways. In cases where we share your Personal Data with authorized government institutions and/or other institutions designated by the government or cooperating with us, you acknowledge and agree that the retention of your Personal Data by these institutions will follow their respective data retention policies.
To the extent permitted by the Applicable Laws and Regulations, you release us from and against any and all claims, losses, liabilities, costs, damages, and expenses (including but not limited to legal fees and full compensation costs) directly or indirectly resulting from any activities conducted outside of our Services.
YOUR RIGHTS AS A PERSONAL DATA SUBJECT
You may have certain rights under the Applicable Laws and Regulations to request access to, correction of, and/or deletion of your Personal Data that is in our possession and control.
We may deny your request for access, correction, and/or deletion of some or all of your Personal Data that we hold or control if permitted or required under the Applicable Laws and Regulations. This includes situations where the Personal Data contains references to other individuals, or where requests for access, correction, or deletion are deemed irrelevant, unreasonable, frivolous, or suspected to be related to violations of terms and conditions or legal infractions.
In accordance with the Applicable Laws and Regulations, we reserve the right to charge an administrative fee for any request for access and/or correction of Personal Data.
SECURITY OF YOUR PERSONAL DATA
The confidentiality of your Personal Data is of the utmost importance to us. We will implement the best efforts, both technically and operationally, to protect and secure your Personal Data from unauthorized access, collection, use, or disclosure. These measures include physical, electronic, and managerial safeguards to prevent unlawful processing, accidental loss, destruction, damage, or similar risks.
Although we use our best efforts to secure and protect your Personal Data, please be aware that data transmission over the Internet is not entirely secure. Therefore, we cannot fully guarantee that your Personal Data will not be intercepted, accessed, disclosed, altered, or destroyed by unauthorized third parties due to factors beyond our control. If a Personal Data security breach occurs that affects your Personal Data, we will, in accordance with the Applicable Laws and Regulations, notify you through our official communication channels, either directly or indirectly, and provide sufficient information regarding the breach. We will also take steps to protect your Personal Data from further misuse.
The security of your Jubelio account also depends on how you maintain the confidentiality of your account password and other access information. Therefore, you are responsible for keeping your account details confidential and must not share them, including your phone number, email, password (as applicable), or one-time password (OTP). You must always ensure the security of the device you use. You release Jubelio from any form of loss or claims arising from your negligence in maintaining the confidentiality of your Jubelio account details, including passwords, emails, and OTPs, as well as your failure to secure your device. We are also not responsible for unauthorized access to the Platform resulting from the loss or transfer of your phone/device to an unauthorized party.
We strive to verify you and your Personal Data to ensure optimal accuracy, completeness, and consistency of data. By agreeing to this Privacy Notice, you release us from any claims related to the accuracy, completeness, and/or consistency of any data, without eliminating our obligation to make reasonable efforts for correction.
The obligation to maintain the confidentiality of Personal Data will not apply or will no longer apply to Personal Data that:
- Was already publicly known at the time of disclosure or became publicly known afterward by means other than through our actions or negligence;
- Was disclosed with your authorization; and/or
- Must be disclosed under applicable laws and regulations, court decisions, or the orders of authorized government institutions in any jurisdiction.
GOVERNING LAW
This Privacy Notice is governed by the laws of the Republic of Indonesia, and you are required to comply with all Applicable Laws and Regulations in the Republic of Indonesia.
UPDATES TO THE PRIVACY NOTICE
This Privacy Notice may be modified and/or updated from time to time to ensure that it aligns with business developments and/or changes in legal regulations. In this regard, Jubelio may notify you of such changes and/or updates in accordance with the provisions of the Applicable Laws and Regulations. However, you are expected to regularly check this Privacy Notice page to stay informed about the most recent version of this Privacy Notice.
You agree that you are fully responsible for periodically reviewing this Privacy Notice page to stay updated on the latest information regarding how we process Personal Data. By continuing to access or use the Platform, communicate with us, or purchase any Services after any changes to this Privacy Notice, you will be deemed to have accepted and agreed to this Privacy Notice and all its updates.
CONTACT US
If you have any questions, comments, complaints, or claims regarding this Privacy Notice, or if you wish to exercise your rights as a Personal Data subject regarding your Personal Data on the Platform, please send an email to [email protected]. We will handle your complaint confidentially. We will contact you within a reasonable period after receiving your complaint to discuss it and provide options on how your complaint can be resolved.
I HAVE READ AND UNDERSTOOD ALL THE TERMS IN THIS PRIVACY NOTICE AND ITS CONSEQUENCES AND HEREBY ACCEPT ALL RIGHTS, OBLIGATIONS, AND TERMS SET FORTH IN THIS PRIVACY NOTICE. THIS STATEMENT IS DEEMED AS MY CONSENT AS THE OWNER AND/OR GUARDIAN OF PERSONAL DATA.
