This Privacy Statement (“Privacy Statement”) describes how AQUA 10 liter program (“Program” or “We” or “Us”) collects and manages Your Personal Data. This Privacy Statement contains information about what data we collect, how we use it and why we need it.
This Privacy Statement applies to Personal Data collected by AQUA in connection with Your access to the website that can be accessed via the link address https://www.sehatAQUA.co.id/AQUA10liter (“Microsite”) and your participation to the Program and does not apply to websites, applications and/or other platforms managed by AQUA. Contact us through the information in the Contact section if You have any questions and comments, or if You want to make a request regarding Your data subject rights.
Acceptance of Privacy Statement
Please read this Privacy Statement carefully before accessing Microsite or participate to the Program. By accessing or participate to the Program, You have read carefully, understood and agreed to the terms and conditions, including this Privacy Statement and the Terms and Conditions in connection with Program. If You do not wish to comply with this Privacy Statement, please do not accessing the Microsite or not to participate to the Program.
We reserve the right at any time to change this Privacy Statement, and such changes are effective after posting through Microsite. You, as Participant to the Program, are responsible for carefully reading these terms before accessing to the Microsite or participate to the Program. By accessing to the Microsite or participate to the Program further is a form of approval for changes to the Privacy Statement on the Program.
We also have the right to replace, change, suspend and/or discontinue all or any part of this Microsite and/or Program at any time or after giving notice as required by applicable laws and regulations. We may launch certain services or features in beta, which may not function properly or the same as the final version and we are not responsible for such.
We may also restrict certain features or restrict Your access to parts or all of the services in our sole discretion and without notice or liability. We reserve the right to refuse to give You access to the Program or Microsite for the Program for any reason.
Our Basic Principles and Privacy Commitment
We are committed to protecting Your privacy right. We aim to protect any Personal Data in our possession, to manage Your Personal Data responsibly and transparently in our practices. Your trust is important to us. Therefore, we are committed to the following basic principles:
- You have no obligation to provide the Personal Data requested by us. However, if You choose to not to do so, we may not be able to provide you with some services or products;
- We only collect and process Your data for the purposes set out in this Privacy Statement or for certain purposes that we share with You and/or which You have agreed to;
- We aim to collect, process and use as little Personal Data as possible;
- When we collect Your Personal Data, we aim to keep the data as accurate and precise as possible;
- If the Personal Data we collect is no longer necessary for any purposes and we are not required by law to retain it, we will do what we can to permanently delete, destroy or de-identify it.
- Your Personal Data will not be shared, sold, rented or disclosed other than as described in this Privacy Statement.
Who Collects?
Any Personal Data provided to or collected by PT. Tirta Investama, PT Tirta Sibayakindo PT. Tirta Investama, PT Sarihusada Generasi Mahardhika, PT Nutricia Indonesia Sejahtera, and PT Nutricia Medical Nutrition either directly or through a third party We designate, which is entirely controlled by Us, and/or other companies affiliated with the Danone group in Indonesia, as personal data controllers (“AQUA”).
This Privacy Statement applies to Personal Data collected by AQUA related to the services on the Program through Microsite. This Privacy Statement does not apply to AQUA marketing content, including offers and advertisements for AQUA products and services, AQUA promotional activities, which we (or service providers acting on our behalf) send to You on third party websites, platforms and websites based on Your site usage information. These third party websites generally have their own Privacy Statement and Terms & Conditions. We encourage You to read them before using the website.
Basis for Obtaining and Processing Personal Data by AQUA
In managing the Program, AQUA is Personal Data Controller who collects Your Personal Data based on legal basis in accordance with applicable laws and regulations, and will depend on the type and purpose of collecting Personal Data.
For the purposes of this Privacy Statement, Personal Data referred to here is data about natural persons who are identified or can be identified individually or in combination with other information either directly or indirectly through electronic or non-electronic systems in accordance with the provisions of the Personal Data regulations in force in Indonesia.
In general, we collect and process your Personal Data based on several bases, including:
- Your consent to this Privacy Statement;
- Carrying out our obligations based on legitimate interests while taking into account the objectives, needs and balance of our interests and your rights.
- Carry out our obligations as controller of Personal Data in accordance with laws and regulations.
If you have any questions about this, please contact us on the contact details provided in the "How to Contact Us" section below.
What Personal Data Do We Collect?
In general, we may collect the following types of Personal Data (“Personal Data”) from You:
- Personal contact data, such as Your name, email, work/home location, birthdate, child’s name, phone number, and/or other relevant personal information.
- Account login details, including user ID, email username, phone number and password. The information is required to create private account in one of our online community.
- All communications, including your interaction to us.
- Demographic information, including age, gender and Your lifestyle preferences. Your lifestyle preferences include your preferences on our products and Your interest to our products.
- Browser history, such as access page, access date, Your location when access, and IP address.
- Social media profile, if You share it to us.
In addition to the information above, we collect indirect information when:
- You share content in social media pages, websites, or any related mobile application related to our products or as response to our promotion materials in social media; or
- We read or collect Your Personal Data by reading collected information from other websites (eg. We may place ads in a third-party website, and when You click the ads, we may collect any information about You and other website visitors to measure reach and success rate).
Why Do We Collect and Use Your Personal Data?
We collect your Personal Data in regards with Program in order to comply with AQUA’s internal policies and/or requirements.
In particular, by giving consent, You agree that we may collect, store, use, and/or disclose Your Personal Data (including the designated parties or parties who cooperate with AQUA) for the following purposes:
- To process and answer Your question or to contact You to answer Your questions and/or requests.
- To develop and improve our products, services, communication methods and effectiveness of our Program.
- To communicate information for You and manage Your registration and/or subscribe to our newsletter or other communications.
- To manage our daily business per Your participation on contests, lucky draw, other promotional events that we hold.
- To authenticate/verify Your identity, Your child, and/or someone who reach out to us by phone, electronic devices, or other channel.
- To deliver information for You with any means of communication (mail, email, telephone, SMS, WhatsApp, and any) related to milk products for child above 12 (twelve) months or pregnancy milk products or family milk products and/or other products of AQUA’s affiliations, but not limited on information and materials in relation to parenting tips and children’s growth development, product or brand launching, change on product packaging, marketing activity and/or milk product regulations, within the scope of law.
- To process private information in a country outside the country You register (eg. Database location in a country and remote access from other country)
- To use feedbacks, comments, pictures, stories, and/or writings that You send to website for any purposes, including but not limited for communication and promotional materials both internal and external AQUA.
- For internal training and quality assurance purposes.
- To understand and assess interest, demand, and changes of consumer needs, to improve our existing websites, products and services, and/or improve new products and services.
- To provide personalized products and communications and product recommendations for You as customers.
- To be stored in databases that we can use for the purposes mentioned above, without divulging Your identity.
- To disclose Your personal information to AQUA service providers for the purposes mentioned above and/or AQUA affiliates and/or third parties appointed by AQUA to do the above things for its own purposes as well as (if required by law) to the competent authorities.
- We may also need Your Personal Data to comply with legal regulations or in the context of contractual relations we have with You.
When we collect and use Your Personal Data for purposes mentioned above or any other, we will inform You before or when it happened.
Information Regarding Children and Persons with Disabilities
In implementing the Program, we will only collect and process Personal Data for Users over 17 years of age and legally competent to act for and on behalf of themselves. In the Program,
If due to any reason, you as a User do not fulfill these requirements, including but not limited to, if you are under 17 years of age or have a disability, then you guarantee that you have obtained approval from your parents or guardian and/or other appropriate approvals. required in accordance with applicable legal provisions.
How Long Will Personal Data Be Stored?
Your Personal Data is used and processed as permitted by law or based on Your consent, and such data will be retained only for as long as necessary to fulfill the stated purposes under applicable regulations until You withdraw Your consent. However, if it is required under any law or regulation that Program is required to retain data for a longer period of time, then Program will retain the Personal Data for a period of time in accordance with these provisions.
We may retain your Personal Data to provide the services you request, or for other legitimate interests, such as complying with our legal obligations under laws and regulations and obligations from government authorities, resolving legal issues, and/or carrying out our relevant business operational activities. The retention period for Personal Data is based on applicable legal requirements. However, if there are no relevant laws and regulations, your Personal Data will be stored for the time necessary. Furthermore, we may store this Personal Data in hard copy or electronic form.
We may store your data in data centers or archive storage spaces managed by us or by data storage service providers, for and on our behalf. All of our storage locations, systems and products are equipped with the necessary security controls to ensure the protection of Personal Data.
Retention periods may vary based on the type of information and legally required retention periods, the course of judicial proceedings, needs in the conduct of business, implementation of intellectual property rights, agreements, operational needs, and archiving. In the event that your Personal Data is deleted from our systems, it will be deleted or destroyed using appropriate security protocols so that it cannot be reconstructed or read again by parties not authorized to do so.
Your Rights
Subject to the relevant prevailing laws and regulations, You can exercise Your rights below, through the information in the How to Contact Us section.
Right to Clarity of Identity
You have the right to obtain information regarding clarity of identity, basis of legal interest, purpose of the request and use of Personal Data, and our accountability, as the manager of the Program who manage your Personal Data.
Right to Complete and/or Make Corrections
You have the right to complete, update, and/or correct errors and/or inaccuracies in your Personal Data at any time. You can exercise some of these rights directly through the Program, or by following the information in the How to Contact Us section.
Right to Access Personal Data
You have the right to request a copy of the Personal Data we hold about you. To make this request as an individual or authorized third party, you can visit the How to Contact Us section which provides details on how to do so.
The Right to Delete Your Personal Data
You have the right to request us to delete Your data if:
- Your Personal Data is no longer required in connection with the purposes for which we collected it; or
- You withdraw the consent that you had previously given us to process Your Personal Data, and there is no other legal basis for processing that Personal Data; or
- You have objected to us processing Your Personal Data for direct marketing purposes; or
- You have objected to us processing Your Personal Data for AQUA legitimate interests (such as improving the overall user experience on our website or Microsite); or
- Personal data is not processed legally; or
- Your Personal Data needs to be deleted to comply with the law.
If You want to delete the Personal Data we hold about You, please contact us through the information in the How to contact Us section, and we will take reasonable steps to respond to Your request in accordance with legal requirements.
If the Personal Data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to permanently delete, destroy or de-identify it.
Right to Withdraw Consent
You have the right, in certain circumstances, to withdraw consent to the processing of Personal Data that you previously provided by manner in the How to Contact Us section. However, the unavailability of your Personal Data means that we are unable to verify and process your activities in connection with the use of features on the Program page, so that you may not be able to use certain services.
If you still want to use the Services on the Micrositepage, then you can only withdraw partial consent to the use of Personal Data that is not used to provide services to you.
To Opt-Out from Marketing Information on Products
If you no longer wish to receive marketing information from us, you can opt out at any time. If you previously chose to receive personalized content based on how and where you use our network, you can also opt out of receiving it at any time..
The way to opt-out of marketing activities is by contacting us via How to Contact Us and other mechanisms that we provide from time to time.
If you choose to opt-out, you may still receive service-related messages.
Please note that you may still receive offer messages for 3x24 hours after selecting opt-out. This can be caused by the time it takes for us to update our database.
You may also have received marketing information from us even though you are not a user or have never had any contact with us. If you have registered with us to opt-out of our marketing information, you must not receive such communications. If you still receive it, we ask that you immediately notify us by contacting our customer service team. This will only stop marketing information from Us and does not stop third parties sharing your data unless you contact them directly.
Right to Automatic Processing
You have the right to object to decision-making actions that are based solely on automated processing, including profiling, which give rise to legal consequences or have a significant impact on you as a Personal Data Subject.
If you wish to exercise this right, please contact us using the information in the How to Contact Us section and we will take reasonable steps to respond to your request in accordance with legal requirements.
Right to Delay or Restrict Processing
You have the right to delay or limit the processing of your Personal Data, if:
- you do not believe that the Personal Data we hold about you is accurate; or
- the Personal Data is not being processed lawfully, but instead of deleting the Personal Data, you would prefer that we restrict processing instead; or
- we no longer need your Personal Data for the purposes for which we collected it, but you need the data to establish, exercise or defend legal claims; or
- You have objected to the processing of your Personal Data and are awaiting verification whether your interests related to the objection outweigh the legitimate reasons for processing your data.
If you wish to restrict the processing of your Personal Data, please contact us using the information in the How to Contact Us section and we will take reasonable steps to respond to your request in accordance with legal requirements.
Data Portability Rights
Your personal data is portable. This means it can be moved, copied, or transmitted electronically. However, this right only applies if:
- Processing is based on your consent;
- The ongoing process for contract implementation;
- The process takes place automatically; and
- As long as it meets the legal requirements and technical provisions applicable to data portability.
If you wish to exercise your right to data portability, please contact us using the information in the How to Contact Us section.
How We Protect Your Personal Data
We understand that the security of Your Personal Data is important. We make our best efforts to protect Your Personal Data from misuse, interference, loss, unauthorized access, modification or disclosure. We have implemented a number of security measures to help protect Your Personal Data. For example, we implement access controls, use firewalls and secure servers, and we encrypt Personal Data
Sharing Personal Data
When we share Your Personal Data with affiliates and other organizations, we ensure we only do so with organizations that secure and protect Your Personal Data and comply with applicable privacy Act in the same or similar way that we do.
Your Personal Data will not be shared, sold, rented, or disclosed other than as described in this Privacy Privacy Statement. However, we may share Your data for legal purposes and/or when required by government authorities.
We work with our other partners to provide services as part of fulfilling our obligations to You. When we share your Personal Data with our partners, we implement necessary measures to limit the use of your Personal Data to lawful reasons in accordance with this Privacy Notice, as well as adequate confidentiality and security measures. Apart from these purposes, we also share information with third parties to fulfill our legal obligations when requested by government authorities and to handle legal processes, to protect your vital interests, to carry out tasks in the public interest when requested by government authorities, public services , or the exercise of our authority based on statutory regulations, as well as to fulfill other legitimate interests by taking into account the objectives, needs and balance of our interests and your rights.
Sharing Personal Data Internationally
Personal data can be processed outside the territory of the Republic of Indonesia. When processed outside the territory of the Republic of Indonesia, AQUA will ensure that this cross-border data processing is protected by adequate safeguards.
We do not share your Personal Data, except in the following circumstances:
- To AQUA and/or Danone group companies, if necessary, and within the limits of applicable legal regulations
- As required by law, such as when related to judicial processes, dispute resolution, and/or similar legal processes.
- To protect our rights and protect your security.
- With our business partners in providing our services, such as application and system developers who work for us.
- With our business partners in marketing activities for our products or services, in which case no raw Personal Data is provided, because the information provided has generally been combined into aggregate data or anonymous data.
- With third parties for educational, research and scientific development purposes.
In such cases, the relevant third parties must agree to strict obligations to maintain the confidentiality of Personal Data in accordance with applicable agreements and/or other relevant legal documents and use them only for the purposes for which the information was obtained.
Automated Decision-Making and Profiling
For some services and products, we may process Your Personal Data using automated means (including profiling). Basically, this means that decisions are taken automatically without human intervention. Automatic decisions are decisions regarding the provision and offering of services that are made automatically based on the results of algorithmic calculations, without any human intervention. We may also process your Personal Data for profiling purposes to predict your behavior on our websites/Microsites or products that may be of interest to you.
We use automated analysis to make predictions such as the types of products or services you may be interested in, or for profiling. The artificial intelligence we use can lead to automatic processing of your Personal Data in various ways. If our automated decision-making initiatives or plans have significant consequences for you, we will implement measures to protect your rights, freedoms and interests or obtain your consent as required by laws and regulations.
Cookies and Other Technologies
We may also collect Personal Data about You through the use of cookies and other technologies. This may occur when You visit our sites or third-party sites, or use our third-party mobile websites and may include the following information:
- Information about Your device browser and operating system;
- IP address of the device you are using;
- Web pages or our Microsite that you view or access;
- Links that You click when interactive with our services.
Technical and Operational Security.
We strive to process your information in a secure environment by preventing unauthorized or unlawful access. We also protect your Personal Data from loss or damage. We have implemented various types of physical, technical and administrative safeguards to protect your Personal Data and our network from unauthorized access. These steps include:
- Encryption in transit or at rest.
- Strict compliance with Data and Personal Data security practices.
- Information Security Management System Certification (Information Security Management).
- Regular data audits and reviews according to our operational standards.
- Operational security, including: installing antivirus software, creating back-ups and storing in a safe environment.
- Restrict access to Personal Data to only personnel who have a need to know the data.
We also require our suppliers and vendors to implement similar protections when they access or use the Personal Data we share with them. We also always encourage you and all Program users to protect the data, systems, networks and services they use. However, no technology, data transmission or system can be guaranteed to be 100% secure. Therefore, if you discover or become aware of a Personal Data leak, please immediately notify us in the manner listed in the “How to Contact Us” section below.
How to Contact Us
If You have any questions, comments or complaints regarding this Privacy Privacy Statement or the processing of Your Personal Data, please contact us through the following :
AQUA MENYAPA :
RDTX Place Lt.8
Jl. Prof. DR. Satrio Kav. 3,
Kel. Karet Kuningan, Kec. Setiabudi,
Jakarta Selatan, 12940
Telepon : 0800-15-88888
By providing your Personal Data to us, you agree that:
- You have read and understand this Privacy Statement and agree to the use of your Personal Data as set out in this Privacy Statement.
- In the event that you provide us with Personal Data relating to another individual (such as your partner, family member, friend or other party), you represent and warrant that you have obtained the consent of that individual to, and hereby consent to the individual's name for use of that Personal Data as set forth in this Privacy Statement.
- All Privacy Statements Your privacy statements are true and correct to the best of your knowledge, and you do not intentionally omit related information that is detrimental.
- The consent you give to us is provided freely without any coercion from any party.
Applicable law
This Privacy Statement is subject to the laws of the Republic of Indonesia. This Privacy Statement is made in Indonesian and English. If there are differences or conflicts between the Indonesian and English versions, the Indonesian language will apply and the English version will be deemed to have changed to conform to the Indonesian version.
How Do We Update This Privacy Statement?
We will update this Privacy Statement as necessary to meet customer requests and adapt to changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the top of this Notification. If the changes are significant, we will provide more prominent notices (including, for certain services, email notifications of changes to the Privacy Notification).
Additional Terms or Privacy Statement
In addition to this Privacy Statement, there may be specific terms that will be governed by additional terms or privacy statements. We advise You to read these additional terms or notifications, if any, before participating to the Program/accessing to the Microsite.
Disclaimer :
We do not guarantee that access to this Program page is uninterrupted, error-free, virus-free, or that this Application is secure. We are not responsible for any losses arising from actions related to the use of the information presented. Risks arising from the User's reliance on the information displayed in this Microsite will be the User's responsibility.
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(last updated on 13 November 2024)