Consumer Privacy Policy

​Surplus (PT Ekonomi Circular Indonesia) is committed to respecting your privacy.
Our Privacy Policy sets out 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 enforcing your rights under 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 natural person. An identifiable person is someone who can be identified, directly or indirectly, in particular by reference to an Identifier such as a name, identification number, location data, online identifier or to one or more specific factors such as physical, physiological, genetic, mental, economic , the cultural or social identity of a 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, addresses IP and standard web log information;
• Details of the products and services we have provided 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 use of our website/App or online presence or through another website or account for which you allow us to collect information;
• 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 by lawful and fair means and not by unreasonable means. In general, 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 carry out 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 16 years of age.

We may also collect personal information from you when you fill out an application form, communicate with us, visit our website, give us feedback or complete an online application. 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 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 any or all of our services as requested. We require individuals to provide accurate, up-to-date and complete personal information when registering/logging in to our website/App.

​4. What is our legal basis?

We have a legal basis under Law Number 19 of 2016 as well as KOMINFO Ministerial Regulation No. 20 of 2016 concerning the protection of personal data in electronic systems (PM 20/2016). We rely on several legal bases to process your personal information, including:

• Where necessary to provide you with access to, and use of, products, Services and websites/applications;
• For our legitimate interests to provide, operate and improve our products, Services or website;
• 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 the purposes for which the information was collected, or for directly related purposes, (but not limited to):

• Providing our website/application, products and services to you;
• Administer, protect, improve or optimize our website/applications, products and services (including performing data analysis, conducting research and for advertising and marketing purposes);
• Charge you to purchase or use our website, products and services;
• Inform you about our website, 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 to which you have agreed; And
• Any use required or authorized by relevant privacy laws.

​6. Disclosure of Personal Information

We may disclose your personal information to:

• Third parties with whom we have collaborated from time to time to perform functions on our behalf for the above purposes;
• Any person or entity to whom you have expressly consented to us disclosing your Personal Information to:
• Our advisors, auditors, attorneys, 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 relevant Privacy Laws.

7. Access And Management

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

If you believe that we hold personal information about you that is not accurate, complete, or current, 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 destroy your personal information.

8. Direct Marketing

Where are we:

• Have express consent (which you can withdraw at any time by contacting us);
• Has a legal basis; Or
• If not permitted by privacy laws
• 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 can opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive 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 communication, or by contacting us in writing at cs@surplus.id

​9. Cross-Border Disclosure

When conducting transactions with us, you have consented to your personal information being disclosed or transferred to such recipients. We will take all 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 Number 19 of 2016 as well as KOMINFO Ministerial Regulation No. 20 of 2016 concerning the protection of personal data in electronic systems (PM 20/ 2016).

​10. Site/App Surplus

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

Surplus websites/apps may use ‘ cookies ‘ or other similar tracking technologies on our websites that help us track your website usage and remember your preferences. Cookies are small files that store information on a computer, TV, mobile 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 through 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 either electronic or hard copy. We take reasonable steps to protect your personal information from misuse, interference 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 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 User Personal Data

Surplus has the control to delete User Personal Data if (i) User Personal Data is no longer needed to fulfill the initial need for which it was collected; and (ii) there are applicable laws and regulations that need to be complied with regarding the storage of User Personal Data.

If users have concerns regarding potential violations or misuse of User Personal Data by Surplus, Users can contact Surplus via Surplus user services at email cs@surplus.id by explaining the identity and complete details regarding user complaints regarding potential misuse of User’s Personal Data. Surplus will investigate and follow up on reports submitted and may delete User Personal Data in accordance with applicable legal regulations.

​13. Others

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

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