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Consumer Privacy Policy

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

Our Privacy Policy  determine how we collect, use,

process, store, share and disclose your personal information.

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 as follows:
your full name;
e-mail address;
telephone number;
Your device ID, device type & geo-location information

3.  Collection

We will collect Personal Information only in a lawful and fair manner and not in an unreasonable manner. Generally, we will collect personal information directly from you and only to the extent necessary to provide our products and services requested or ordered by you and to perform our administrative functions or as required by the relevant Privacy Laws.


We will not collect sensitive personal information (as defined in the 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, give us 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 permission to the third party to share it 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 you with any or all of our services as requested.


If you wish to remain anonymous while using our website/app, do not log in or provide any information that could identify you. We require individuals to provide Personal Information that is accurate, current and complete at the time it is collected.

4.   What is our legal basis?

We have a legal basis based on Law No. 19 of 2016 and Minister of Communication and Informatics Regulation No. 20 of 2016 concerning 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/Apps; for our legitimate interests 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 where 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, including (but not limited to): providing our website/App, products and services to you; manage, protect, improve or optimize our websites/Apps, products and services (including performing data analysis, conducting research, and for advertising and marketing purposes); bill you to purchase or use our websites, products and services; notify you of websites, products, services, awards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners; respond to any questions or comments you send us; verify your identity; any other purpose to which you agree; and any use required or permitted by the relevant Privacy Act.

6.   Disclosure of Personal Information

We may disclose your Personal Information to: third parties whom we normally engage from time to time to perform functions on our behalf for the above purposes; any person or entity that you expressly consent to us disclosing your Personal Information; our external business advisors, auditors, lawyers, insurance companies and 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 the 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 explaining why we did so.


We may charge a reasonable fee that is not excessive to cover the cost of retrieving your Personal Information from our customer account database. We will not charge you for making the request.


If you believe that we hold Personal Information about you that is inaccurate, complete or up-to-date, then you may 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 the relevant Privacy Laws, we will take steps that are reasonable in the circumstances to destroy your Personal Information or to unrecognize it. .


8.   Direct marketing

Where we: have your consent (which you can withdraw at any time by contacting us); have a legal basis; or otherwise permitted by the relevant Privacy Laws, we may use and process your Personal Information to send us information about products and services that we believe are relevant to you and your interests or we may invite you to attend special events. At any time you may choose not to receive direct marketing communications from us. Unless you opt-out, your consent to receive direct marketing communications from us and to the handling of your Personal Information as described above, will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communications, or by contacting us in writing at


9.   Cross-border disclosure

When making transactions with us, you expressly and freely consent to your Personal Information being disclosed or transferred to Recipients. We will take steps reasonably necessary to ensure that 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 the relevant Privacy Laws (including Law Number 19 of 2016 as well as Regulation of the Minister of Communication and Information No. 20 of 2016 concerning Protection of Personal Data in Electronic Systems (PM 20/2016).

10.   Surplus Sites/Apps

When submitting Personal Information from your computer to a Surplus website/Application, you should remember that the transmission of information over the Internet is not always completely secure or error-free. Apart from liability that cannot be excluded by law, we will not be liable in any way for any breach of security or the accidental loss or disclosure of such 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 placed the cookie 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 Surplus website/App.

11.   Security

We may store your Personal Information in electronic or printed form. 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 any 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.  Deletion of the User's Personal Data

Surplus has the control to delete the User's Personal Data if (i) User's Personal Data is no longer needed to fulfill the initial need for its collection; and (ii) there are laws and regulations that need to be complied with in relation to the storage of the User's Personal Data.

If the user has concerns regarding the potential of violation or misuse of the User's Personal Data, the User can contact the Surplus via the Surplus customer service at by explaining the identity and complete the details of the complaint of potential misuse of the User's Personal Data. The Surplus Party will investigate and follow up on the submitted report and may delete the User's Personal Data in accordance with the provisions of the applicable legal regulations.

13.  Etc

We reserve the right to change this Privacy Policy in whole or in part from time to time without notice and amendment and will take effect immediately upon posting the modified Privacy Policy on the Surplus website/App


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