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Privacy Policy For Business

Surplus (PT Ekonomi Circular Indonesia) is committed to respecting your privacy.

Our Privacy Policy sets out how we collect, use,

processing, storing, sharing and disclosing information  your personal.

1.   Openness And Transparency

We are committed to protecting your privacy and respecting and upholding your rights under the consumer protection law no. 8 1999 or other applicable national regulations. We ensure that we will take all necessary steps to comply with relevant privacy laws and to address inquiries or complaints from individuals regarding compliance with relevant privacy laws.  


By accessing and using our website, products and or services, you freely and expressly consent to the collection, use, processing, storage and disclosure of personal information to us as set out in this privacy policy.

2.   Personal information

Personal information is information that relates to an identified or identifiable individual. An identifiable person is someone who can be identified, directly or indirectly, in particular by reference to an identifier such as name, identification number, location data, online identifier or to one or more specific factors such as physical, physiological, genetic, mental, economic , culture or social identity of the natural person.


The types of personal information we collect from you include, without limitation, the following:

  • Your Full Name;

  • Address

  • Email address;

  • Phone number;

  • Email & Website;

  • KTP & NPWP;

  • Your device ID, device type, Geo-location information, computer and connection information, statistics on page views, traffic to and from the site, advertising data, IP address and standard web log information;

  • Details of the products and services we provide to you or that you have requested, including any additional information necessary to provide those products and services and respond to your inquiries;

  • Any additional information relating to you that you provide to us directly through our website or application or indirectly through the use of the website/App or our online presence or through other websites or accounts that you allow us to collect information from;

  • Information you provide to us through customer surveys;

  • Billing information (including credit and bank details); Or

  • Other personal information that may be required in order to facilitate your transactions with us.

3.  Collection

We will collect personal information only in a lawful and fair manner and not in an unreasonable manner. In general, we will collect personal information directly from you, and only to the extent necessary to provide our products and services that are requested or ordered by you and to perform our administrative functions or as required by relevant privacy laws. We will not collect sensitive personal information (as defined under relevant privacy laws) from you. We also do not knowingly seek or collect personal information from children under the age of 16.


We may also collect personal information from you when you fill out application forms, communicate with us, visit our websites, provide us with feedback or complete online. We may collect personal information about you that you have provided to our business partners or from third parties and in connection with which you have given the third party permission to share with us.


If you use a pseudonym when dealing with us or you do not provide us with identifiable information, we may not be able to provide any or all of our services as requested. We require individuals to provide accurate, current and complete personal information at the time of registering/logging in to our web/App.

4.   What is our legal basis?  

We have a legal basis under Law No. 19 of 2016 as well as Minister of Communication and Information Technology No. 20 of 2016 concerning the protection of personal data in electronic systems (PM 20/2016). We rely on several legal grounds to process your personal information, including:


  • Where necessary to provide you with access to, and use of, products, services and websites/applications;

  • In our legitimate interest to provide, operate and improve our products, services or websites;

  • Where you have freely and expressly consented to our processing of your personal information, which you may withdraw at any time; Or

  • We are under a legal obligation to process your personal information.

5.   What Do We Do With Your Personal Information?

We use, process and disclose your personal information for information collection purposes, or for directly related purposes, (but not limited to):


  • Provide you with our website/application, products and services;

  • Manage, protect, improve or optimize our websites/apps, products and services (including performing data analysis, conducting research and for advertising and marketing purposes);

  • Billing you to purchase or use our websites, products and services;

  • Inform you about our websites, products, services, rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;

  • Respond to any questions or comments you submit to us;

  • Verify your identity;

  • Other purposes that you have agreed to; And

  • Any use required or authorized by the relevant privacy law.

6.   Disclosure of Personal Information

We may disclose your personal information to:

  • Third parties we have partnered with from time to time to perform functions on our behalf for the above purposes;

  • Any person or entity that you have expressly consented to us disclosing your Personal Information to:

  • Our advisors, auditors, lawyers, insurers and external business financiers; And

  • Any person or entity to whom we are required or authorized to disclose your Personal Information in accordance with the relevant Privacy Laws.


7.   Access And Management

Subject to some exceptions provided by relevant privacy laws, you may request access to your personal information in our customer account database, or seek correction, by contacting us. See section 13: contact information. If we deny you access to your personal information, we will provide a written explanation setting out our reasons for doing so.


We may charge a reasonable and reasonable fee to cover the costs of retrieving your personal information from our customer account database. We will not charge you for making a request.


If you believe that we hold personal information about you that is inaccurate, complete or up-to-date, then you can request that your personal information be changed. We will respond to your request to correct your personal information within a reasonable time and you will not be charged for correcting your personal information.


If we no longer need your personal information for any of the purposes set out in this privacy policy, or as required by relevant privacy laws, we will take steps to have your personal information removed.


8.  Direct Marketing

Where are we:

  • Have an express consent (which you can withdraw at any time by contacting us);

  • Have a legal basis; Or

  • If not allowed by privacy law

we may use and process your personal information to send you information about products and services that we believe are suitable for you and your interests or we may invite you to attend a special event.

At any time you may opt out of receiving direct marketing communications from us. Unless you opt-out, your consent to receiving direct marketing communications from us and the handling of your personal information as described above, will continue. You can opt out by following the instructions included in the relevant marketing communications, or by contacting us in writing at

9.   Cross-Country Disclosure

When you make a transaction with us, you have consented to your personal information being disclosed or transferred to that recipient. We will take steps reasonably necessary to ensure your personal information is treated securely and in accordance with this privacy policy. We use reasonable efforts to ensure that each recipient who receives your personal information is bound by relevant privacy laws (including law No. 19 of 2016 as well as Minister of KOMINFO Regulation No. 20 of 2016 concerning protection of personal data in electronic systems (PM 20/ 2016).

10.   Site/App Surplus

When transmitting personal information from a computer to a website/App Surplus, you should remember that the transmission of information over the internet is not always secure or error-free. Apart from liability that cannot be excluded by law, we will not be liable in any way in connection with security breaches or accidental loss or disclosure of information.


Surplus websites/apps may use 'cookies' or other similar tracking technologies on our website which help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, phone or other device. They allow the entity that places cookies on your device to recognize you across different websites, services, devices and/or browsing sessions. You can disable cookies via your internet browser, but if you do, you may not be able to fully experience the interactive features of the website/App Surplus.


11.   Security

We may store your personal information in both electronic and hard copies. We take reasonable steps to protect your personal information from misuse, tampering and loss, as well as unauthorized access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information.


However, we cannot guarantee the security of personal information transmitted over the internet and therefore you disclose the information to us at your own risk. We will not be responsible for any unauthorized access, modification or disclosure, or misuse of your personal information.


12.   Contact Information

If you require further information regarding our privacy policy or wish to make a privacy complaint, please contact us at


13.  Etc

We reserve the right to modify this Privacy Policy in whole or in part from time to time without notice and the Amendments will take effect immediately upon posting of the modified privacy policy on the surplus website/App.

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