PRIVACY POLICY OF PT HPP ENERGY INDONESIA

 Updated as of: [21.12.2023]

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In this policy (“Privacy Policy”), we, PT HPP Energy Indonesia (hereinafter referred as “HEIN”) set out, how we collect, receive, use, store, possess, deal, or handle your Personal Data when you use our mobile application, website, and services (“Services”). We value the trust placed in us by our users, and therefore, we take significant efforts to protect your Personal Data, including Sensitive Personal Data. 

References to “We”, “Our” or “Us” or the “Company” shall mean the Services and/or HEIN. Any references to “You”, “Your” or “User” shall mean any person or entity using our Services.

This Privacy Policy is a part of and is to be read with HEIN Terms of Use (“Terms”).  By using the Services, you agree to the terms and conditions of this Privacy Policy. If you do not agree with the terms and conditions of this privacy policy, please do not use this application.

This policy shall be executed in English and in Indonesian, but in the event of any inconsistency between the two versions of this Agreement, English language prevails in all respects.

Alternatively, should you have any questions or clarifications, please reach out to us at the details provided in paragraph 12 below.

 

1. THE DATA WE COLLECT AND HOW WE USE IT

Data we collect from you

Log-in and registration Data

At the time of registration, we collect the following data from you:

  • name
  • your customer ID number
  • contact details (mobile number and email address)
  • date of birth
  • password
  • identification documents (KTP Card, driver License, Address Proof)
  • gender(M/F/X)
  • address
  • NIK/SIM-C/NPWP and details

 

Service usage data

We and certain third parties on our behalf may also collect the following data about you and your use of our Services and your interactions with us:

  • location data
  • advertising ID from third parties
  • IP address
  • battery related information
  • device tokens for push notification (if you have enabled push notifications) interactions on emails, communications, messages, advertisements and certain third-party platforms and other channels information that you provide to our customer support team
  • camera information
  • device data
  • transaction information: such as date, time, and amount of the transaction payment.

 

Location Data

Location data is information that is derived from your GPS and/or IP address.

We may collect relevant information from third parties for the purposes set out above. These include:

  • your OEM (such as vehicle data)
  • third party service providers in relation to the Services (such as the rescue and breakdown services)
  • contractors
  • third party data sources and public repositories

 

Data for Contact Us Feature

We collect information about general inquiries, including HEIN's company profile, corporate activities, and services, from contact points, including inquiries on the website. These include:

  • your name
  • your company name
  • your contact information including E-mail address and Phone number
  • communication information including inquiry

 

How we use it

Log-in and registration Data and Service usage data

The data we collect from you and will be shared to some of our third parties, insofar permissible under the Applicable Laws will be used for the following purposes:

  1. to provide, maintain, improve and support our Services, and to enable us to provide new services.
  2. to solve problems in the use and operation of services, prevent unauthorized use, fraud detection and analytics, provide network and information security.
  • to research, analyse and understand the users, to perform analytics and conduct customer research.

 

Location Data

To provide you with services such as informing you of available nearby swapping stations, and in relation to rescue services.

 

Data for Contact Us Feature

To provide appropriate information and respond appropriately to inquiries.

We may collect relevant information from third parties for the purposes set out above.

Such data will be used for the purposes set out in this Privacy Policy.

 

2. DISCLOSURE

In processing User’s Personal Data, we are committed to maintain the confidentiality of the User’s Personal Data. At times, we may share your Personal Data (but not Sensitive Personal Data (e.g. passwords etc.)) with certain trusted partners, for the purposes set out below or for purposes are same as in paragraph 1.

 Certain key data sharing partners include: 

  • Honda Motor Co., Ltd.
  • Honda Motor Co., Ltd Group Companies
  • PT Astra Honda Motor

 

Further, we may also share your Personal Data with the following entities and for the purposes set out below:

  • Others working for and with HEIN.We uses certain trusted third parties (for example, providers of customer support, IT services, rescue services for your vehicles) for the business purposes of helping us provide, improve, protect, and promote our Services.
  • Our business partners and group companies. We may share your data with our business partners or group companies    in connection with the purposes set out in first sentence of this paragraph 2.
  • Partnerships with research and development institutions. We may share your data with entities engaged in research and development in connection with the purposes set out in first sentence of this paragraph 2.
  • Law & Order and the Public Interest.We may disclose your data to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; (b) prevent, detect, report, and investigate potentially prohibited or illegal activities, including data breaches, fraud, and enforcing our terms; (c) protect HEIN’s rights, property, safety, or interest; or (e) perform a task carried out in the public interest.
  • HEIN’s successors or assigns. If another company acquires our company or our assets, that company will possess your information including Personal Data, and will assume the rights and obligations with respect to that information as described in this Privacy Policy. If we are involved in a merger, acquisition, bankruptcy, reorganization, or sale of assets such that your information would be transferred or become subject to a different privacy policy, we will notify you of such actions in advance.
  • HEIN’s legal or contractual obligations. We may share your data from time to time if required, to enforce or apply our Terms and/or any other agreements.

 

3. SECURITY

We have in place appropriate technical and security measures to secure the data collected by us and shared with our trusted partners, as disclosed above. We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Data including sensitive Personal Data against unauthorized access, loss, destruction, or alteration.

We would also ask you, the user to keep the data in relation to the Services (e.g., user id, passwords, payments data) confidential and secure.

We use commercially reasonable security practices and procedures industry practices and procedures designed to help keep your Personal Data safe and secure. Some of the safeguards we use to protect your data include anonymization of your personal data and aggregation of data prior to sharing with third parties, where required. Unfortunately, the transmission of data over the Internet is not completely secure. Although we strive to protect your Personal Data, we cannot guarantee the security of your data while it is being transmitted, due to factors beyond our control. You are responsible for keeping your account details confidential and you must always maintain and fully responsible for the security of the device that you use. 

As you are aware, we may share your data with third parties, such as our vendors and suppliers, who may share such data further (for permitted purposes). We will ensure, on a commercially reasonable efforts basis and through contractual protections, that such data is shared in accordance with Applicable Laws.

 

4. WHERE WE STORE YOUR DATA

We protect every User’s Personal Data stored in the system, and protect such Personal Data from any unauthorized access, use, modification, collection and/or disclosure by using a number of security measures and procedures. 

Your data may be transferred to or may be maintained on computers, computer systems and computer resources located outside Indonesia where the privacy laws may be different (but no less stringent than the restrictions imposed by Indonesian law) from those, where you live. We shall ensure that the same level of data protection is adhered to, where your data is transferred or maintained. 

 

5. CHANGES TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time and will post the most current version on our website. If a revision meaningfully modifies your rights, we will notify you prior to such changes.

 

6. YOUR CONTROL AND ACCESS OF YOUR DATA

You have control over your personal data and how it’s collected, used, stored, processed, and shared. You are free to update data that you registered on the app by yourself from your user account at any point in time. You may correct, amend, add, or delete Personal Data. However, the history of your activities and account remains available to us. Further deletion of data (such as payments data) may result in us, suspending the services being provided to you.    In case you do not agree with the privacy policy after giving your consent, it means you withdraw of the service. If you require to update your data that is not registered by yourself on the app, you need to contact us.

 

7. DATA RETENTION

We do not retain your Personal Data for longer than is required for the purposes for which the data may be lawfully used.

Your Personal Data will be deleted and destroyed based on the Applicable Laws, provided that (i) the User’s Personal Data is no longer required to fulfil the purpose of its collection; (ii) the User has withdrawn their consent to the processing of their Personal Data; (iii) based on a request of the Personal Data’s owner or the User; (iv) such Personal Data are obtained and/or processed in an unlawful manner; (v) lapsed of the retention period; or (vi) not related to settlement of the legal process of a case.  

 

8. THIRD PARTY LINKS

The application may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates and/or any other websites or mobile applications. If you follow a link to any of these websites, please note that these websites have their own privacy policies.

We are not responsible or liable for the collection or use of personal data in applications or services provided by a third-party and recommend that you carefully review applicable terms for (and any integrity policy related to) such applications or services before you use them. If you have questions concerning a certain third party's use of your personal data, please contact the third party directly.

 

9. APPLICABLE LAWS

The terms and conditions set forth herein are subject to the laws of the Republic of Indonesia.

 

10. COMMUNICATIONS FROM US

We may from time to time send you announcements and updates when we consider it necessary to do so (such as for promotional activities, updates, or key events such as suspension of the Services, maintenance, or security, privacy, or administrative-related communications). We send these to you via SMS, messaging platforms, emails among other means.

You may opt out from unwanted message or e-mail communications from us by following the instructions provided in such message. However, until your account is deleted you will continue to receive all system related messages (such as for major updates, changes in terms, etc).

 

11. COMPLAINTS RELATED TO PROTECTION OF USERS’ PERSONAL DATA 

If you have any concern with regard to the handling or treatment of User’s Personal Data or in the event you believe that your Personal Data has been breached, you may contact HEIN through HEIN’s contact provided in this Privacy Policy by describing the issue and complaint of you as the User.

 

12. CONTACT US

If you have any grievances/questions about this Privacy Policy, the Services or your dealings with us, you can contact PT HPP Energy Indonesia [info@hppenergy.co.id] or write a letter to us at the below address:

 

[Midplaza 2 11th Floor, Jl. Jenderal Sudirman No.Kav. 10-11, Karet Tengsin, Kecamatan Tanah Abang, ,Kota Jakarta Pusat, Daerah Khusus Ibukota Jakarta 10220 INDONESIA].