INTRODUCTION
PT Central Sudirman Development (“Company”, “our”, “us” or “we”) are committed to protecting your privacy and safeguarding your personal data in our possession. This Privacy Policy (“Policy”) transparently explains how, when, and why we use your personal data, as well as your rights regarding the usage of such personal data when you visit our website (twosudirman.com) and/or when you interact with us. We only collect and use your personal data as outlined below.
This Policy is only intended for our individual customers. By using our services and/or interacting with us, you acknowledge that any personal data you provide to us is true, complete, lawfully obtained, and that you are fully entitled to provide such personal data to us. By using our services, you are deemed to have read and understood this Policy.
THE PERSONAL DATA WE COLLECT
The types of personal data we collect from you will depend on the specific type of services and products as requested by, or provided to, you. The types of personal data may include (without limitation) the following (“Personal Data”):
- your personal information (e.g. your name, gender, date of birth, passport or other personally identification card number);
- your contact information (e.g. telephone numbers, mailing addresses, email addresses, postal code and fax numbers);
- your business information (e.g. company name, business title and associated contact information);
Certain Personal Data (e.g. relating to your personal information and contact information) are required for specific services and if you fail to supply such Personal Data as requested from each specific service, we may not be able to deliver you the services or products. By providing your Personal Data to us, you acknowledge that such provision is fair and reasonable in the circumstances.
PURPOSES OF YOUR PERSONAL DATA COLLECTED AND USED
The purposes for which your Personal Data are collected and used may include (without limitation) one or more of the following purposes:
- for the supply of any services, products, facilities and/or other subjects (together, the “Services”) which we or any of our subsidiaries, holding companies, joint ventures and associated companies (together, “ PT Central Sudirman Development”) may offer to you, or you may require from us, from time to time;
- for use of the online services available at any of the websites of PT Central Sudirman Development and/or through other telecommunication channels;
- with your consent, for marketing or promoting any of the Services of PT Central Sudirman Development (e.g. sending you updates on our latest offers and promotions in relation to any of our Services from time to time);
- for identification and verification purposes in connection with any of the Services that may be supplied to you;
- for reservations with or through us or any member of PT Central Sudirman Development for communicating with you by email, mail, fax, phone or other means, including contacting you regarding your enquiries;
- for managing customer relationship and relationship with PT Central Sudirman Development’s Merchants;
- for making disclosures when required by law, regulation, or court order of any jurisdiction and/or as requested by any government, regulatory or law enforcement authority or administrative organization, which may be within or outside Indonesia.
- for establishing legal claims or defenses, obtaining legal advice, and/or exercising, defending and/or protecting the rights or properties of any member of PT Central Sudirman Development, including identifying, contacting or bringing legal action against any person who may be causing interference with such rights or properties (whether intentionally or otherwise) or where any other person could be harmed or property of any other person could be damaged by such interfering activities;
- for any other incidental or associated purposes relating to the above, or any other purposes as specified in a personal information collection statement when your Personal Data is being collected, or any other purposes which you may agree with from time to time.
We will not knowingly or intentionally use, share or sell your Personal Data in ways which are unrelated to the above purposes (or purposes as specified in a personal information collection statement when we collect your Personal Data) without your prior consent.
DISCLOSURE AND TRANSFER OF PERSONAL DATA
To facilitate the purposes mentioned above, we may transfer, disclose, grant access to or share your Personal Data with third parties located within or outside Indonesia, and your Personal Data may be transferred within or outside Indonesia. These third parties may include the following:
- any member of PT Central Sudirman Development;
- any agent, contractor or third-party service provider who provides administrative, marketing, research, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to or support the operation of PT Central Sudirman Development’s business (including its/their direct marketing activities);
- other business associates such as loyalty programme operators and other companies involved in providing customer service or fulfilling customer requests;
- credit reference agencies, credit, debit and/or charge card companies and/or banks;
- medical professionals, clinics, hospitals, insurers and/or loss adjustors;
- any person, government or law enforcement authority or administrative organisation;
- any person under a duty of confidentiality to any member of PT Central Sudirman Development (including accountants, legal advisers or other advisers);
- any actual or proposed assignee or purchaser of all or any part of the business and/or asset of PT Central Sudirman Development; and/or
- charitable or non-profit making organisations.
The Personal Data you provide to us may also be sourced from or transferred to other jurisdictions outside Indonesia for the purposes mentioned above.
DIRECT MARKETING
If we intend to use your Personal Data (including your name and contact details) collected from you for direct marketing purposes (e.g. to send you marketing communications about news, offers or promotions in relation to the Services or Activities of PT Central Sudirman Development or its Merchants), we will first obtain your consent (or an indication of no objection) before doing so.
We may issue service-related announcements to you when necessary (e.g. when we suspend a service due to system maintenance). You may not be able to opt out of these announcements which are service-related and not promotional in nature.
OUR COMMITMENT TO CHILDREN’S PRIVACY
Protecting the privacy of children is our primary concern. Hence, generally, we will not knowingly collect or maintain Personal Data from persons who are under 17 years of age without prior consent from a parent or guardian.
Specifically, in Indonesia, we will not knowingly collect or maintain Personal Data from persons who are under 14 years of age without prior consent from a parent or guardian; and will only collect or maintain Personal Data from persons between 14 and 18 years of age if explicit consent has been obtained from such person or his/her parent or guardian.
USE OF COOKIES AND LOG FILES
If you visit any of our websites, we may use cookie files to store and track information about you and your preferences. A cookie is a small text file that our website transfers to your computer’s or device’s hard disk. We use cookies to better serve you and/or maintain your information across multiple pages within or across one or more sessions. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future. However, if you disable cookies or refuse to accept a request to place a cookie, certain functionalities on our websites may not be available.
Cookies contain information about you and your preferences. For example, if you inquire about rates and availability, the site might create a cookie that contains the details you entered. Or it might only contain a record of which pages within the site you visited, to help the site customise the view for you the next time you visit.
Only the information that you provide, or the choices you make while visiting a website, can be stored in a cookie. For example, the site cannot determine your email name unless you choose to type it. Allowing a website to create a cookie does not give that or any other site access to the rest of your computer, and only the site that created the cookie can read it.
We may also collect information regarding your IP address, browser type, domain name and access time. This information is used for our own research purposes. As it is not linked to any personal information, it is separate from your Personal Data.
In rare instances, IP addresses may be used to assist in deterring and/or preventing abusive or criminal activity on the website. If you use the WiFi available at our properties, we may collect your location data (if you have consented to this on your device). We may use your location data to keep track of your activity patterns and preferences in order to improve the level of service you receive. Your location data may be combined with other information we receive from third parties to provide you with better service and, where you have consented to receive direct marketing, we may provide you with targeted advertisements, content, features, deals and offers in relation to the classes of marketing subject as set out in the relevant personal information collection statement when your Personal Data is being collected.
If you interact with us on social media platforms (for example if you “Like” our Facebook Page or post on our timeline), we can interact with you and send you messages via these platforms. We will interact with you in accordance with the social media platform’s rules but we are not responsible for how the platform operators collect and handle your Personal Data. We are not responsible for what third parties post on our social media accounts.
DATA RETENTION
Subject to any legal, statutory, regulatory or accounting requirements, the Personal Data you provide to us will be kept by us in the appropriate form only for as long as is necessary to fulfill the purposes mentioned above after which it will be destroyed.
DATA SECURITY
In order to ensure the correct use and to maintain the accuracy of the Personal Data collected from you, as well as preventing unauthorised or accidental access, processing, erasure or other use of the Personal Data, we have implemented various internal policies (including physical, electronic and management measures) to safeguard and secure the Personal Data we collect. For example, where we collect Personal Data online, we use an industry standard for encryption over the Internet known as Secure Socket Layer (SSL) protocol, to protect the Personal Data.
We endeavor to improve our standards of protection; however, you acknowledge that we are not liable for any losses arising from the destruction or loss of your personal data that occurs beyond our control. Therefore, we recommend you to keep your software up to date and to not disclose your account password to any parties.
Unfortunately, the transmission of information via the internet is not completely secure. You also acknowledge that we cannot guarantee the integrity and accuracy of any personal data you transmit over the internet, nor can we guarantee that such personal data will not be intercepted, accessed, disclosed, altered, or destroyed by unauthorised third parties due to factors beyond our control.
In the unlikely event that we believe the security of your personal data in our possession or control may have been compromised, we may notify you at our sole discretion. If notification is appropriate or required by the Personal Data Protection Regulations, we will endeavour to do so as promptly as possible under the circumstances, but no later than the statutory deadline for notification under the Personal Data Protection Regulations after becoming aware of the issue. We may notify you by email or other means of communication based on the contact information provided to us. By using this website, you consent to our use of email as a means of such notification.
THIRD-PARTY SITES/APPLICATIONS
Our services or communications with you (for example via social media) may from time to time contain links to third-party websites, applications, plug-ins or services over which we have no control. Certain activities on our website, such as special promotions, may also be connected to third-party companies that offer you the option to share your personal data with them. We will not share your personal data with these third-party companies; only you can do so if you choose.
Links to third-party websites provided on our website are offered for your convenience. However, we do not control those websites or their personal data protection practices, which may differ from ours. If you access these third-party links, please note that such third parties have their own personal data protection activities and notices. We recommend you to read such third-party personal data protection notices to understand your rights.
Some third-party companies may choose to share their personal data with us, but that sharing is governed by such third party company’s personal data protection notice. We are not responsible for any activities, including data processing activities that occur on systems belonging to third parties
GOVERNING LAW AND DISPUTE RESOLUTION
This Policy is regulated and interpreted according to the laws and regulations of the Republic of Indonesia.
Any Dispute shall be resolved by the relevant parties amicably and by deliberation to reach consensus within 30 (thirty) calendar days of a party receiving a written notice of such dispute from the other party.
If the Dispute cannot be resolved by the parties within 30 calendar days from the date of the written notice under Section 16.2 above, then such Dispute will be referred to and finally resolved by binding arbitration administered by BANI in accordance with the administrative and procedural Arbitration Rules of BANI in force at the time, which rules are deemed to be incorporated by reference in this section. The seat of the arbitration shall be Jakarta, Indonesia. The tribunal shall consist of an arbitrator appointed by the Head of BANI. The language of the arbitration shall be English.
NOTIFICATION AND COMMUNICATION
We may send you messages by email, post, telephone, text message, and/or other digital methods (messages that appear on your mobile device), as well as through new methods that may become available in future.
These messages serve the purpose of:
- fulfilling our legal obligations, such as regarding changes to the agreement with you and notify when there is an incident of failure to protect your personal data;
- informing you about the features and benefits of the products and services we provide to you; and
- informing you about products and services (including from other companies) that may be of interest to you. Messages like these are marketing messages. You can ask us to stop or start sending you marketing messages at any time by contacting us through our contact details as set out in Section 18 of this Policy.
CONTACT US
If you have any questions or concerns regarding this Policy or your personal data, please contact us at:
- Email : info@twosudirman.com
- Address : Jl. Jendral Sudirman Kav. 2, Jakarta 10220.
Additional rights may be available to you depending on the location of your residence or of our operations. If you would like to exercise any of your rights or obtain a copy of any of your Personal Data, or if you believe that any of your Personal Data which we collect and maintain is inaccurate or would like to request for information regarding our policies and practices and the kinds of Personal Data held by us, please contact us at the following address:
TWO SUDIRMAN PRIVATE RESIDENCE – SALES GALLERY, JL JEND SUDIRMAN KAV 2, KARET TENGSIN, TANAH ABANG, KOTA ADM. JAKARTA PUSAT, DKI JAKARTA, 10220
