IMPORTANT

PRIVACY POLICY

We believe you should be able to make informed decisions about your personal data. This “Privacy Policy” explains how PT Selancar Indonesia Raya, its subsidiaries, affiliates and jointly controlled entities ("SOORFINC", "us", "we", or "our") collect, use, process, disclose, transfer, and protect personal data, both through our website www.soorfinc.com and SOORFINC mobile app (the "Site").

“Personal Data” means any information about you, from which you may be identfied whether directly or indirectly, such as your name, nationality, religion, address, date of birth, occupation, phone number, e-mail address, bank account and credit-card details, gender, government issued identification number of our users and non-users in your mobile phonebook, health data, financial related information, and biometric information.

This Privacy Policy applies to SOOFINC users, vendors, agents, suppliers, partners, contractors and service providers ("you", "your", "yours"). Please take a moment to review and understand this Privacy Policy and contact us if you have any questions.

(01)

Personal Data We Collect

This section sets out the types of Personal Data that we collect and reasons for such Personal Data collection.

a. Data Collected Whenever You Use the Site

(i)

When you use the Site, we collect Personal Data which identifies or can be used to identify, contact, or locate the person or device to whom that information pertains. Without collecting it, we are not able to provide you with our services or achieve the intended purpose of our transaction with you. The Personal Data we collect from you include (but is not limited to) your:

full name,
email address,
phone number,
address and/or location,
identification or passport number,
your travel / surfing preferences,
details of your surfing particulars and preferences, and/or
your reviews.

(ii)

In some cases, we will request you to provide us with a government-issued document(s) as part of our know-your-customer process if required under the applicable laws or our Terms & Conditions to identify you.

(iii)

If you utilize any payment and/or transactional services on the Site either to make a payment or receive any payment, we will collect certain Personal Data related to the payment and/or transactional services you used. Those data include (but are not limited to): payment card number or account identifier, payment card or account holder, sender and receiver details, goods/services transacted on the Site, and history of transactions.

b. Data Collected from You to Process Your Registration and Account Management

(i)

When you register and create an account on the Site, we request you to provide us with certain Personal Data including but not limited to your full name, phone number and email address.

(ii)

If you are a registered user, we might request you to provide your SOOFINCuser identification and login credentials in order to access your account.

c. Data Automatically Collected from Your Device by Using Our Site

(i)

Whenever you use the Site, we will collect Personal Data in the form of technical data regarding your device and device usage such as information about web pages viewed, session duration, the internet device identity (ID) or media access and other information such as:

Geographic location: we will collect information about your actual location, whether or not you are using the Site, to provide you with the offers in the relevant location as provided in the Site. We may also derive your approximate location from your IP address and GPS and other information provided from your mobile device.
Log Information: when you are using the Site, we will collect information which we refer to as "log information". The log information may be collected even though you do not create an account on the Site. This log information may include (but is not limited to) IP address, browser type, operating system, nationality, pages visited, your mobile carrier, device information and search history as well as other Internet usage related information. We use the log information to provide you with a better experience using the Site.
Cookies and similar technologies: we use cookies and similar technologies (such as web beacons, tags, scripts) to collect information. A cookie is a small piece of data that is stored in your computer or mobile device to help us track your internet usage. We use cookies in certain email notifications we send after a purchase/reservation of goods/services on the Site has been made (e.g. to learn your behaviour and experience in our Site, such as whether the email notification was delivered and opened and whether links within the email were clicked). In addition, we use cookies to give you a better experience using the Site and so the Site will recognize you when you use the Site in the future. Please deactivate the cookies option if you wish us to stop the cookies feature and kindly note that if you deactivate cookies, you may not be able to access all or part of the Site, or to use all or part of the functionality through the Site.
Device and Installed Application Information: the data and information from your phone and/or from the installed apps on your device may be collected to provide a segmented risk profile and generate aggregated statistical information. To protect your identity, we remove all personal identifiers (if any) and pseudonymised such information. Any metadata processed in this way cannot be used to reproduce the original data collected.

(ii)

If you are a registered user, we might request you to provide your SOOFINCuser identification and login credentials in order to access your account.

d. Third Party Personal Data You Provide to Us

(i)

You may provide us with Personal Data relating to other third-party individuals (including whenyou add any third-party individual data in the Site). In that case you undertake and warrant to us that you have already obtained properly documented approval from the relevant third-party individual and hereby consent on behalf of such individuals to the collection, use, disclosure and processing of his/her Personal Data by us.

(ii)

If we are unable to collect your Personal Data, we may not be able to provide our services to you.

(02)

How We Use Your Personal Data

use of Personal Data is necessary for compliance with legal requirements; and/or
use of Personal Data is necessary to protect Your vital interest or our legitimate interest (including but not limited to purposes stated herein).

To provide our services to you and improve your experience on our Site, we may collect, hold, use and disclose your Personal Data for the following reasons and as permitted by the applicable laws:

identifying you as user which include registering, maintaining and managing your account on our Site;
offering you with advertisement suitable for your preferences;
verifying your account, transaction, and/or registration as we may, in our sole discretion necessary before providing services in the Site;
managing, operating and administering the Site;
contacting you regarding your use of, and access to the Site and managing the queries and requests submitted by you through the Site;
customizing your experience when using the Site;
measuring and improving your customer experience and satisfaction including providing you with direct or personalizing marketing activities, and providing or offering services from us or our business partners;
monitoring and analysing your activities, demographic data, behaviour, search queries, response time for the various services provided in the Site, and any Personal Data you provided to the Site in order to support and improve the performance, user experience, growth, and functions of the Site. We will anonymize your Personal Data (or using other method as required by the applicable laws) before we process it for these purposes;
detecting and preventing money laundering, terrorism financing, fraud, abusive behaviour, harmful or illegal activity including to comply with the applicable laws, respond to legal requests, and protect our rights;
publishing your reviews about our services as well as the listed products on the Site;
enforcing the provisions of the SOORFINC Terms & Conditions;
resolving disputes, collecting outstanding payment and troubleshooting; and
for any other purposes that we notify you of when we collect the Personal Data.

How we use your Personal Data for marketing activities:

digital marketing which includes, but is not limited to, social media, display advertising, search engine optimization, search engine marketing and push notification (for example, using open graph techniques, etc.);
conventional marketing purposes which include, however is not limited to, sending you emails about new products, special offers, surveys and/or other information which we think you may find them interesting;
registering your use of, access to, and creation of an account/accounts to the site/application of our subsidiaries and/or affiliated companies; and
migration of your reviews on our Site to the site/application of our subsidiaries and/or affiliated companies (“Migration Process”).

Please note that you may opt out of receiving marketing materials from us including MigrationProcess by following the unsubscribe instructions set out in our marketing materials or by contacting us on the contact details set out below and we will respect your wishes. However, please note that:

we may target and personalise our recommendations and other contacts that we display on the Site based on your Personal Data,
we may still send you non-promotional messages, and
the opt out will take into effect within 7 (seven) Business Days after you successfully unsubscribe from the service.

(03)

Sharing of Your Personal Data

We may share your Personal Data with other companies, organizations and individuals including our subsidiaries and affiliates (each a "Third-Party") in connection with providing our services to you and to our other customers and for any of the following purposes as well as for such other purposes if permitted by applicable law:

to help facilitate interactions between users;
to perform or deliver a service/feature in the Site;
to Third-Party (including agents, advisers, vendors, suppliers, contractors, partners and any others who perform any process on our behalf, provide services on the Site, provide services to us or whom we collaborate with) in relation to any verification, authentication, risk assessment, fraud prevention and product development and maintenance as we or other Third-Party may consider necessary before you providing you with the services including any activities related to anti-money laundering and counter terrorism financing prevention and credit eligibility checking;
in relation to the transaction process in the form of merger, consolidation, change of controlor ownership, restructuring and/or sale of company assets of our business, then your Personal Data may be disclosed and transferred as part of the transaction (even if the transaction is eventually not proceeded with);
in relation to our services, we share Personal Data to providers of website hosting, data analysis, marketing, promotions, processing credit card transactions, assessment of credit worthiness, and other relevant services;
to help facilitate the verification process with any Third-Party providing services on our Site.

We will notify you if we need to and seek your consent if we need to additionally collect, use or process your Personal Data for other purposes other than expressly stated in this Privacy Policy.

Please note that we will disclose your Personal Data subject to the following conditions:

Contractual Obligation: You agree, accept and are bound by this Privacy Policy and SOORFINC Terms & Conditions when using our services available on the Site. Other than the contractual obligations under SOORFINC Terms & Conditions, we will apply other legal basis or your consent to disclose and process your Personal Data.
Consent: We will only share your Personal Data with the Third-Parties when we have your consent to do so.
For Legal Reasons: We may also, in our absolute discretion, share your Personal Data with Third-Parties (including government agencies, law enforcement, and lawyers and other advisers) if we consider this is necessary to: i) comply with applicable laws and regulations; ii) investigate any potential fraud or illegal acts; or iii) protect our brand, our reputation and our property.

(04)

Cross Border Data Transfer

Services provided through the Site can be used around the world. To make that possible, your Personal Data may be transferred to or accessed by entities around the world. In this regard, SOORFINC will comply with laws on the transfer of Personal Data between countries to help ensure your data is protected, wherever it may be.

We may also transfer your Personal Data located overseas including to any Third Party. In any case, we will take appropriate steps to ensure that your Personal Data remains subject to a standard of protection comparable to the requirements under the laws of your country.

(05)

Access to or Correction of Your Personal Data

When you provide us with your Personal Data, please ensure that it is accurate and complete. If you believe that any of your Personal Data held by us contains errors or omissions, please log into your account on the Site and correct the Personal Data. In addition, please update your Personal Data through your account in a timely manner, should there be any changes.

If you wish to correct an error or omission in any of your Personal Data held by us which cannot be corrected via your account on the Site, or to access your Personal Data held by us which cannot beaccessed via your account on the Site, please submit your request to our contact details listed below.

If mandated by the applicable law, you may request certain copies and/or access of your Personal Data, that you have provided to us in a structured, commonly used, and machine-readable format. If you wish to obtain a copy of your Personal Data, please contact digital@soorfinc.com.

(06)

Your consent

By accepting this Privacy Policy, you acknowledge that you have read this Privacy Policy and the SOORFINC Terms & Conditions and understand their content and consequences, and you agree and give consent to us for the collection, use, disclosure, and processing of your Personal Data in accordance with this Privacy Policy and/or the SOORFINC Terms & Conditions. Further, you acknowledge that the Personal Data that you have provided or will provide is yours to share and is true and accurate.

From time to time, we may revise this Privacy Policy to reflect changes in the laws and regulations, our use practices, the features of our Site and/or advances in technology. If we make revisions thatchange the way we collect or use your Personal Data:

we will notify you of any such amendments by means of a general notice published on the Site, or otherwise to your e-mail address set out in your account,
those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy, and
your continued use of the Site, communications with us, or access to and use of the services following any amendments to this Privacy Policy will constitute your acceptance to this PrivacyPolicy and all its amendments.

Where we have obtained your consent for any collecting, use or disclosure as indicated above, youmay withdraw your consent to our collection, use or disclosure of your Personal Data by submitting a request at our contact details listed below. Upon your request, we will promptly cease to collect, use or disclose your Personal Data, unless required by law or if we have legitimate business or legal purposes for collecting, using or disclosing such Personal Data.

Depending on the circumstances and the nature which you are withdrawing, please note that by withdrawing your consent to our collection, use or disclosure of your Personal Data, we may not beable to continue providing you with some of our services and you agree that we will not be liable to you for any losses or damages arising out of or in relation to such termination of services.

(07)

Removal of Your Personal Data

To the extent permitted by applicable law, you may have the right to request us to remove your Personal Data that we hold from our systems. You may submit a deletion request to us at our contact details listed below.

We, without undue delay or within time period as stipulated under the applicable law, shall use reasonable effort to erase your Personal Data, or will use reasonable efforts to remove the means or personal identifiers by which the Personal Data can be associated with you as an individual, if:

the purpose for which Personal Data was collected is no longer being served by the retention of that Personal Data;
we are not otherwise permitted or required by applicable law to retain the Personal Data; and/or
In case it is mandated by applicable law, based on your request to delete your Personal Data.

Please note that by requesting us to remove your Personal Data, we may not be able to continue providing you with some of our services and you agree that we will not be liable to you for any losses or damages arising out of or in relation to such termination of services.

(08)

Retention of Your Personal Data

Unless we remove your Personal Data from our systems following the receipt of a request from you, your Personal Data will be retained by us for as long as your account is in existence, and as needed to provide you with our services, and/or for our legitimate business interests, or for as long as such retention is obligated or authorised by applicable law. We will delete your Personal Data after a 5 years or longer period as required by applicable laws and regulations from the date you terminated/de-registered your account with us.

(09)

Protection of Your Personal Data

We will protect your Personal Data by maintaining reasonable security arrangements, including physical, technical, and organizational procedures, to prevent unauthorized access, collection, use,disclosure, copying, modification, disposal or similar risks. It is important to remember that even though we have several safeguards in place to protect your information, nothing within the internet is 100% secured and we cannot guarantee the safety of your Personal Data. If we are subject to a data breach that relates to your Personal Data, to the extent required by applicable law, we will notify you through our channels, whether directly or indirectly, to give you sufficient information regarding such data breach and will work to protect against the misuse of your Personal Data.

(10)

Links to Other Websites

The Site may contain links to other websites. You should note that we do not have any control oversuch other websites. Please note that we are not responsible for the privacy policy or practices of such other websites and advise you to read the privacy policy of each website you visit which collects any of your Personal Data.

(11)

Registration and Memberships

The Site allows you to create a user account based on the information you provide. By providing that information, registering, and creating your account, you warrant that:

The information you provide is true and accurate, current and complete as required in the registration form on the Site (the "Registration Data"); and
You will update your Registration Data to keep it true, accurate and complete.

(12)

Complaints

If you have a complaint regarding the treatment of your Personal Data by us, please contact us at our contact details listed below. We will treat your complaint in a confidential manner. We will contact you within a reasonable time after receipt of your complaint to discuss it and to outline options regarding how your complaint may be resolved. If you have a complaint regarding the treatment of your Personal Data that is not resolved by us, you may be able to make a complaint tothe relevant regulatory authority. Any Personal Data that we collect while processing or resolving your complaint will be used solely for that purpose.

(13)

Our Contact Details

If you have questions about our Privacy Policy or privacy practices, or would like to submit a complaint, you can contact us at digital@soorfinc.com or call +62 811 392 3777.