Privacy Policy

This Privacy Policy governs the Personal Data that We collect, Our purposes, and Your rights regarding the processing of Personal Data.

This Privacy Policy is issued by PT Ekagrata Data Gemilang, a limited liability company established under the laws of the Republic of Indonesia and domiciled in Menara Tendean, Floor 22, Unit D & E, Jl. Kapten Tendean No. 20C, Jakarta 12710 (hereinafter referred to as “EDGE DC” or “We”). This Privacy Policy applies to all services and/or websites that We manage, namely https://edge. id/ (“Website”) for individual customers, individuals representing corporate customers, business partners, and individuals representing corporate business partners (“You”).

EDGE DC is committed to protecting Your privacy and Personal Data (as defined by applicable laws and regulations in Indonesia (“Applicable Laws”)). This Privacy Policy explains how We acquire, collect, process, analyze, store, fix, update, display, announce, transfer, disseminate, disclose, delete, and/or destruct (collectively referred to as “process”, “processed”, or “processing”) Your Personal Data.

Categories of Personal Data We collect from You.

In accordance with Applicable Laws, We acquire, collect, process, analyze, store, fix, update, display, announce, transfer, disseminate, disclose, delete, and/or destruct Personal Data classified as follows:

1. Personal profile identification data such as full name, National Identification Number (NIK) for Indonesian citizens (WNI) and foreign nationals (WNA), Tax Identification Number (TIN), immigration documents, gender, nationality, place and date of birth, photo, form of signature (physical signature (wet ink) and/or electronic), and/or biometric data.
2. Correspondence data such as address as per ID, domicile address and status, email address, and telephone/mobile number.
3. Technical data including details of Your use of Our Website such as user ID generated by the Website, in-app order services, in-app search services, and internet protocol (IP) address.
4. Device data including device data such as the type of device You use to access the application, including hardware model, operating system, and its version.
5. Log data including server logs that receive data such as device IP address, access date and time, Website features or pages viewed, Website processes, and other system activities, browser type, and/or third-party sites or services You used before interacting with the Website.
6. Location data including real-time geographical location data.
7. Financial and payment data such as bank account details and payment card details such as card or payment account type, card or payment account issuer’s name, card or payment account holder’s name, and SWIFT Code.
8. Other personal data obtained during due diligence activities or the registration of your company to become our business partner.

We do not collect minors’ Personal Data

We do not knowingly collect Personal Data from children under 18 years of age. By using Our services, You represent that You are 18 years or older.

If You are a parent or guardian and You know that Your child has provided Personal Data to Us, please contact Us through the email address listed in this Privacy Policy. If We become aware that We have collected Personal Data from a child without parental consent, We take measures to delete such information from Our servers.

Our Purpose for Processing Your Personal Data.

EDGE DC may process Your Personal Data to provide information transmission services, product notifications, events hosted by Us, and/or newsletters to which You are subscribed to or a customer of the services provided by EDGE DC:

1. to provide You with any service You request or offer;
2. to provide our services and products;
3. to contact or communicate with You via email for the purpose of managing Your use of the Website, Your subscriptions, and/or Your account with Us, Your relationship with Us, or any transactions You make with Us;
4. for marketing purposes, in which case We may provide You with marketing information, advertisements, promotional materials, and/or documents related to products, content, services, and/or events (including those organized by third-party organizations with which EDGE DC may collaborate). EDGE DC (including its affiliates) or such third party organization may sell, market, offer, arrange, be involved in, or promote whether product, services and/or events that is currently existing or will be made in the future by a mode of communication, another form of notification in application or make use of other technology (such as geolocation technology) for Our Website on Your cellular device, in accordance with the applicable laws and regulations on the protection of Private Data in Indonesia. You may choose to not accept/reject or withdraw at any time by sending us an email;
5. to process payments and respond to customer service requests;
6. to conduct research (including customer research), surveys, market surveys, analysis and/or development activity (including but not limited to data analysis and/or profiling) to improve Our services and facilities, or to enhance Our understanding of Your interests, concerns and preferences, improving Our ongoing interaction with You related to the Website or enhancing Our products or services. Notwithstanding the foregoing general terms, in this regard, We may/will send surveys to You or request a face-to-face or phone interview survey through email or postal mail;
7. to execute Your instructions or respond to any queries provided by (or intended to be provided by) You or on your behalf, including to respond to queries and complaints on Your customer services or to respond or handle Your interaction with Us;
8. to monitor, process and/or track Your use of the Website to provide a seamless experience, facilitate or manage Your use of the Website, and/or to help us in improving Your experience in using the Website;
9. using cookies to enhance Our process, advertising, notifications, authentication, security, and compliance analytics and preference management;
10. to comply with applicable legal requirements, including court orders, regulatory body orders, or government requirements, including to comply with a requirement to make disclosures based on legal requirements that are binding to Us, and/or a guideline issued by other regulator or authority in Indonesia, that We must comply with;
11. to comply with government requests or instruction that We must comply with, or respond to request for information from public authorities, ministries, statutory bodies or other similar authorities. For the avoidance of doubt, this means that We may/can disclose Your Private Data to those parties based on their request or instruction;
12. to host, backup (for disaster recovery or otherwise), and maintain Our systems and infrastructure;
13. maintain and develop Our system and infrastructure, including testing and upgrading Our system;
14. to anonymize Your Personal Data. In this regard, You acknowledge that the anonymized data will no longer be considered Personal Data and will no longer be subject to data protection regulations;
15. specifically for Our Customers, to process, validate, manage, or verify Your registration for Our e-newsletter services and to provide You with benefits offered to users;
16. specifically for Our Business Partners, to carry out the scope of cooperation between Us and You and to comply with contractual terms and conditions executed between EDGE and You;

(the purposes mentioned above are collectively referred to as the “Purposes”).

In connection with the communication purposes mentioned above, You acknowledge and agree that such communications by Us may be conducted through correspondence letters, documents, or notices to You, which may involve the disclosure of certain Personal Data about You to facilitate the same delivery, as well as on the outer cover of the envelope/package.

In connection with the marketing purposes mentioned above, You may inform Us at any time that You no longer wish to receive these marketing communications and opt out of certain communications by following the opt-out link or other unsubscribe instructions provided in the email You receive from Us, or by contacting Us through the contact information listed in this Privacy Policy.

EDGE’s Commitment to Protecting Your Personal Data.

EDGE DC is very careful to protect Your privacy. In this regard, We will take reasonable steps to ensure that Your Personal Data remains confidential and secure, and take reasonable technical and organizational measures to protect Your Personal Data from unlawful or accidental destruction, accidental loss, unauthorized or unlawful processing.

All information stored in EDGE DC’s systems is protected from unauthorized access using a number of security measures and procedures, including user passwords, user access management, and encryption mechanisms.

Notwithstanding the above provisions, You acknowledge, understand, and agree that data transmission over the internet is never completely secure, and although We strive to the best of Our ability to secure and protect information from unauthorized access, collection, use, or disclosure by unauthorized individuals and from unlawful processing, accidental loss, destruction, damage, or similar risks, We cannot guarantee the security of any information You provide or send to Us. The risk of providing or transmitting Your Personal Data to Us in this manner is Your own. In the event that Your Personal Data is stolen due to malware and/or viruses originating from Your device, We are not responsible for such risks.

We will also take steps to ensure that Your Personal Data under Our control is destroyed and/or anonymized as soon as it can be assumed that (i) the purpose of collecting Personal Data can no longer be achieved by retaining the Personal Data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) there is a request from You. In any case, the destruction of Personal Data under Our control will occur no sooner than 5 (five) years after the data is collected, unless requested by You before that time.

When and to whom We disclose Your Personal Data?

EDGE DC may/will need to disclose Your Personal Data to any third-party organizations outside of EDGE DC, including Our affiliates, and such organizations may be located (and Your Personal Data may be disclosed) overseas and outside Indonesia, for one or more of the Purposes mentioned above, as those third parties will process Your Personal Data for one or more of the Purposes mentioned above. In this case, You hereby acknowledge and agree that We are permitted to disclose Your Personal Data to such third parties (whether located inside or outside of Indonesia) for one or more of the Purposes mentioned above, and for those third parties to further process Your Personal Data for one or more of the Purposes mentioned above. Such disclosure is subject to appropriate protections for privacy and confidentiality. The third-party organizations to which We typically disclose Your information include:

• third parties with whom We have a commercial relationship with, whether for business, marketing, and/or other related purposes, including those who provide administrative services or other services to Us such as mail houses, call centers, telecommunications companies, logistics companies, IT companies, and data centers;
• market research, marketing, and/or telemarketing service providers;
• Our professional advisors, such as Our auditors and lawyers, and Our insurance companies;
• government agencies, regulatory authorities that require Us to disclose Your Personal Data under Applicable Law or court orders;
• the enforcement of the provisions of the Personal Data Protection Law in Indonesia which includes: (a) national defense and security interests; (b) law enforcement interests; (c) public interest in state administration; (d) interests in monitoring the financial services sector, monetary, payment systems, and financial system stability conducted within the framework of state administration; or (e) interests in statistical and scientific research;
• Our related companies, affiliates, and partners, including but not limited to situations where We receive complaints or claims, for example, against contract manufacturers, infrastructure providers, or other third parties in Our partnerships, which may be located overseas depending on where the related product or its components are produced;
• any actual or proposed transferee or recipient of a business transfer or joint entity if We merge to form such joint entity;
• in the event that Your beneficiaries (if You provide information regarding Your beneficiaries during registration) intend to access Your Personal Data;
• third parties where disclosure by Us to third parties is intended to process Your Personal Data for one or more of the Purposes.

Your Personal Data could be transferred outside the region of Indonesia.

In the event that EDGE DC transfers Your Personal Data outside of Indonesia, EDGE DC will take reasonable steps to ensure that the level of Personal Data protection in the destination country of such transfer is equivalent to (or higher than) the protection of Personal Data in Indonesia.

If the destination country for the transfer of Personal Data does not have an equivalent (or higher) level of protection, EDGE DC may still proceed with the transfer of Your Personal Data as long as it complies with Applicable Law.

EDGE will only retain your Personal Data for a certain period of time.

EDGE DC will only retain your Personal Data for a certain period of time. Your Personal Data will only be stored as long as necessary to fulfill the purpose of collection, during the retention period, or as long as storage is required or permitted by Applicable Law. We will permanently destroy or delete identifying elements from the User’s Personal Data under Our control when (i) Your Personal Data is no longer required to fulfill the purpose of its collection; (ii) the retention period expires; (iii) the storage of Your Personal Data is no longer required for compliance purposes under Applicable Law; and/or (iv) at Your request.

However, please note that some of Your Personal Data may be stored or controlled by third parties, including government agencies in certain ways. If We share Your Personal Data with the authorized government agencies and/or other entities appointed by the authorized government or cooperating with Us, You agree and acknowledge that the storage of Your Personal Data by the relevant agencies will follow the respective data storage policies of those agencies.

To the extent permitted by Applicable Law, You release Us from any claims, losses, liabilities, costs, damages, and expenses (including but not limited to legal fees and full compensation costs) arising directly or indirectly from any activities conducted outside of Our services.

Your rights and how You can exercise it.

EDGE DC takes reasonable steps to ensure that any Personal Data We process is accurate and complete in the event where Your Personal Data is likely to be used by Us to make decisions affecting You or to be disclosed to other organizations. However, it is important for You to inform Us in a timely manner of any changes to Your Personal Data or if there are any errors in the Personal Data We retain about You.

Subject to certain exceptions permitted by Applicable Law, any individual who has provided Personal Data has the right to access or correct that Personal Data. For security reasons, You will be required to submit a request for access or correction of Your Personal Data in writing. You can obtain access to or correction of Your Personal Data by contacting Us at the address listed in this Privacy Policy. We will need sufficient information from You to verify Your identity and the nature of Your request in order to handle Your request.

EDGE DC may charge You a fee to cover Our reasonable administrative costs for handling Your request to access Your Personal Data and will inform You if such event occurs.

For requests to access Personal Data, once We have sufficient information from You to handle the request, We will endeavor to provide You with the relevant Personal Data within the timeframe required by Applicable Law. If We are unable to respond to You within that timeframe, We will notify You as soon as possible of the time by which We can provide the requested information.

For requests to correct Personal Data, once We have sufficient information from You to handle the request, We will address Your request in accordance with applicable data protection regulations in Indonesia, including correcting Your Personal Data within the required timeframe under Applicable Law. If We are unable to do so within that timeframe, We will inform You of the earliest time We can make the correction.

You may withdraw Your consent for the processing of Your Personal Data held by or under the control of Us by submitting Your request to the email address listed below. We will process Your request within a reasonable time of receiving the withdrawal of consent, and thereafter will not process Your Personal Data in the manner stated in Your request, unless permitted by Applicable Law. However, the withdrawal of Your consent may result in certain legal consequences arising from such withdrawal. In this case, depending on the extent of Your consent withdrawal for Us to process Your Personal Data, it may mean that We may not be able to fulfill the transactions You have made with Us or continue Your relationship with Us, or send You the information You requested, depending on the circumstances.

You may request that We stop, delete, and/or destroy Your Personal Data under Our control or possession by submitting Your request to the email address listed in this Privacy Policy. We will process Your request within the required timeframe under Applicable Law, and thereafter We will no longer process Your Personal Data or will destroy Your Personal Data so that We can no longer use it to identify You, unless Applicable Law allows Us to do so.

We may refuse Your request to access, correct, and/or delete part or all of Your Personal Data that We hold or control if necessary or required by Applicable Law. This includes situations where the Personal Data may contain references to others or where access, correction, or deletion requests are made for reasons We deem irrelevant or indicative of violations of the terms of use, unlawful acts, or offenses.

We use cookies in Our Website to provide a good experience for You.

EDGE DC uses ‘cookies’, which are small data files placed by certain Websites on Your hard drive when You visit them. Cookie files may contain information such as a user ID, which the site uses to track the pages You have visited, but the only Personal Data that can be loaded into a cookie is information that You provide Yourself. Cookies cannot read data from Your hard disk or read cookie files created by other sites. Some parts of Our Website use cookies to track user traffic patterns.

Cookies are used to store information, including visitor preferences and the pages on the Website accessed or visited by the visitor. This information is used to optimize the user experience by customizing the content of Our Website pages based on the type of browser used by the visitor and/or other information.

You can set most browsers to notify You if You receive cookies or You can choose to block cookies with Your browser. Be aware that if You choose to delete or block Your cookies, You will lose the ability to save certain preferences, such as Your username and password. If You delete or block Your cookies, You will, for example, need to re-enter Your login credentials to gain access to certain sections of Our Site on each visit.

Third party’s Personal Data provision by You.

If You provide Personal Data of another person other than Yourself to Us (including name, gender, telephone number, email address, domicile address, bank account details, or other data that constitutes Personal Data of related parties, including information or data regarding children if there are children as dependents of Yours or information related to Your beneficiaries that You provide to Us during Your registration), You represent and warrant to Us, and You hereby confirm that:

1. before disclosing the Personal Data of that party to Us, You will and have obtained and have the consent of the party whose Personal Data is being disclosed to Us, to:
   • allow You to disclose that party’s Personal Data to Us for the Purposes;
   • allow Us to process that party’s Personal Data for the Purposes as set forth in this Privacy Policy;
2. You state that You have obtained a valid and explicit approval from such party to provide Private Data of such party to Us and to process such Private Data for the Purposes;
3. You hereby release and indemnify Us from any claims, lawsuits, or demands made by the related party and losses arising if You fail to obtain explicit legal consent and authority from that party to provide their Personal Data to Us and to process that Personal Data for the Purposes.

We strictly prohibit the misuse of third-party personal data to register for Our accounts without the explicit consent and awareness of the data owner, including but not limited to the use of other personal data for Our referral program. Individuals found to misuse the referral program by registering accounts using others’ data without their knowledge will face penalties, including but not limited to account suspension and revocation of any referral benefits obtained through such actions. We reserve the right to investigate and take necessary action to protect the integrity of Our referral program and the privacy of individuals. You must ensure that the parties whose Personal Data You have disclosed have obtained explicit consent from the individuals whose data You are using and must inform those individuals about the use of their Personal Data for registering for Our account.

Corporate Action conducted by EDGE DC and how it relates to Your Personal Data.

Corporate Action conducted by EDGE DC and how it relates to Your Personal Data. We may, in the future, sell or transfer part or all of Our business, operations, or assets to a third party, whether through a merger, acquisition, or otherwise (“Corporate Action”). We may disclose the Personal Data We have obtained from or about You to a potential or actual third-party acquirer, and it may be one of the assets transferred.

In connection with the Corporate Action described above and subject to Applicable Law, We will notify You after such Corporate Action has been officially completed.

This Privacy Policy can be changed from time to time.

EDGE DC has the right to amend this Privacy Policy from time to time. Before making such changes, We will notify You through the Website and/or via email to the address associated with Your account. If You disagree with Our changes to this Privacy Policy, please contact Us through the email address below.

Contact Us if You have privacy-related complains or if You have queries regarding this Privacy Policy.

If You have any concerns or objections regarding Our handling or processing of Your Personal Data, or if You believe Your privacy has been violated, or if You have questions regarding Our Privacy Policy, or if You would like to request access to or correct Your Personal Data, or to withdraw Your consent, please contact or submit Your request to Us at:

Email: pdp@edge.co.id

Consent

By using our Website, you hereby consent to our Privacy Policy and agree to its Terms and Conditions.