Privacy Notice
Privacy Notice
INTRODUCTION

The following Privacy Notice will become effective on 26 April 2024.

This Privacy Notice describes how We, Yayasan Anak Bangsa Bisa as known as GoTo Impact Foundation and/or Our affiliates (“YABB”) obtain, collect, store, control, use, process, analyse, correct, update, display, publish, transfer, disclose, and protect Your Personal Data (“Process Personal Data” or "Processing of Personal Data").

This Privacy Notice applies to all Users (“User” or “You”) of the Website (including www.goto-impact.org and its derivative sites) (“Website”), unless covered by a separate privacy notice.

Please read this Privacy Notice thoroughly to ensure that You understand Our data protection practices. For Your ease of reference and understanding, You may find a summary that highlights all the important points in the Summary section below. All capitalised terms used in this Privacy Notice shall have the same meaning ascribed to them in the applicable Terms and Conditions between You and YABB, as available in the Website.

Acknowledgment and Consent

By agreeing to the Privacy Notice, You acknowledge that You have read and understood this Privacy Notice and agree to its terms. In particular, You agree and consent for Us to Process Personal Data of You in accordance with this Privacy Notice.

In circumstances where You provide Us with Personal Data relating to other individuals (such as Personal Data relating to Your spouse, family members, friends, or other parties), You declare and guarantee that You have obtained consent from those individuals, and hereby consent on their behalf to the Processing of Personal Data of theirs by Us. We may request evidence of such consent from You at any time.

You may withdraw Your consent to any or all Processing of Personal Data at any time by giving Us reasonable notice in writing using the contact details stated in this Privacy Notice. We would like to raise to Your attention that the withdrawal of consent by You may result in Us being unable to provide services, deletion of Your account or termination of Your contractual relationship with Us, with all rights and obligations that arise remaining fully fulfilled. Upon receipt of Your notice to withdraw consent for any collection, use or disclosure of Your Personal Data, We will inform You of the likely consequences of such withdrawal so that You can decide if indeed You wish to withdraw Your consent.

SUMMARY

What data do We collect about You?

We collect Personal Data when You use Our Website, including Identity Data and Contact Data. We also collect Device Data, Technical Data, Log Data, and Lcoation Data from You, and other data that You may submit or transmit when You use Our Website. If You choose not to provide such data, we may not be able to provide services in Our Website to You optimally.

How will We use the data about You?

We use Your Personal Data to set up and manage Your account with Us, communicate with You, and to provide various features, services and functions for You on Our Website.

We also use Your data to maintain Our Website, and for all processes involved in the carrying out of Our programs and events. In addition, We use Your information to market Our Program to You, and those of Our affiliates companies, partners and agents (with Your consent where required by Applicable Laws).

With whom do We share Your data?

We share Your Personal Data with Our third party partners to facilitate the performance of services for or by You, to the extent necessary for them to provide their services, including but not limited to, website maintenance, event organising, research, and publication.

We use these third parties’ services solely to process or store Your data for the purposes described in this Privacy Notice. We also share Your data with Our affiliates for the purposes described in this Privacy Notice and with government and regulatory bodies as required by Applicable Laws.

We may also provide access by displaying Your Personal Data to other Users to facilitate communication and/or implementation of service fulfilment on Our Website.

Where do We process Your data?

We process Your Personal Data only in Indonesia. We may transfer Your data to Our affiliates and third party partners in Indonesia for the purposes as set out in this Privacy Notice.

How long do We process Your data?

We will process Your data for as long as You give Your consent for Us and it is needed to process Your Personal Data to fulfil the purpose for which it was collected and obtained, or as required by Applicable Laws.

How can You exercise Your rights over Your Personal Data?

You may have various rights with respect to Your Personal Data under the Applicable Laws.

If You wish to exercise Your rights, You can submit a data subject rights request to Us by contacting Us at the provided contact in this Privacy Notice.

Contact Us

If You have any questions, concerns or complaints, please contact Us through the contact details that can be found in the Contact Us section.

How will We notify You about changes to this Privacy Notice?

We will amend this Privacy Notice from time to time and notify You of the updated versions through relevant channels, including Our Website or Your registered email with Us. Please check back regularly to see any updates or changes to this Privacy Notice.

More elaboration on the above can be read in the below sections.

1. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

Personal Data” means any data, whether accurate or not, pertaining to any identified or identifiable individual, both individually or collectively with other information, directly or indirectly through electronic or non-electronic systems. Personal Data includes, but is not limited to, name, address, date of birth, occupation, telephone number, email address, gender, identification (including passport or national identity document) or other government-issued identification, photos, nationality, telephone numbers of Users, and other data including as Personal Data in accordance with Applicable Laws. For the avoidance of doubt, applicable laws means all applicable laws, by-laws, statutes, regulations, regulatory policies, ordinances, protocols, industry codes, regulatory permits or court requirements, tribunal, or any governmental, regulatory, judicial, administrative or regulatory authority or body, in force from time to time during the term of this Privacy Notice (“Applicable Laws”). In addition, other data, including personal profiles and/or unique identifiers, are associated or combined with Personal Data, then that data also constitutes Personal Data.

The types of Personal Data that We collect are in accordance with what We need to identify and follow up on the messages You sent through the forms provided on Our Website.

To the extent permitted by Applicable Laws, We may process, collect, use, store and transfer different kinds of Personal Data, consisting of general and specific/sensitive Personal Data, about You which We have grouped together as follows:


  1. Identity Data includes name, username, identity number, user ID or other identifier, title, date of birth, gender, place of birth, occupation, nationality, and/or photos.

  2. Contact Data includes delivery address(es), email address(es) and its label, phone numbers and phonebook.

  3. Technical Data includes details on Your usage of Our Website such as identification generated by the Website (user id), internet protocol (IP) address, data as web pages previously or subsequently viewed, duration of every visit/session, the internet device identity (ID) or media access control address, mobile advertising ID and other device information including information regarding the manufacturer, model, and operating system of the device You use to access the Website and crash logs.

  4. Device Data includes device data, including the type of device You are using to access the Website, including hardware model, operating system and version, software, IMEI number, file name and version, language preference, unique device identifier, advertising identifier, serial number, device movement information, and/or mobile network information.

  5. Log Data includes records on the server that receive data such as device IP address, date and time of access, Website features or pages viewed, Website work processes and other system activities, browser type, and/or third party sites or services that the User used before interacting with the Website.


We may create, use, license or disclose Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from Your Personal Data but would not be considered Personal Data as this data will not directly or indirectly reveal Your identity as We will ensure: (i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, and (ii) the data is then combined with similar data such that the original data forms a part of a larger data set.

2. IF YOU PROVIDE INCOMPLETE PERSONAL DATA

Personal Data” means any data, whether accurate or not, pertaining to any identified or identifiable individual, both individually or collectively with other information, directly or indirectly through electronic or non-electronic systems. Where We need to collect Personal Data by law, or under the terms of a contract We have with You, and You either choose not to provide that Personal Data or provide Us with incomplete Personal Data when requested, We may not be able to provide services and perform the existing agreement or those We are in the process of engaging with You.

3. HOW WE COLLECT YOUR PERSONAL DATA

The Personal Data that We collect may be provided by You directly or by third parties (for example: when You register for or use the Website, or You otherwise provide Personal Data to Us). We may collect data in various forms and for various purposes (including purposes permitted under Applicable Laws).


  1. Data obtained from You directly

    You may give Us Your Identity Data and Contact Data including in situations where requested by Us or where required by Applicable Laws, when interacting with Us directly or by corresponding with Us by post, phone, email or otherwise. This includes Personal Data You provide when You:

    1. register and create an account using the Website; dan
    2. register to one of Our events as a participant, source, or speaker.

  2. Data collected whenever You use the Website

    You may give Us Technical Data, Device Data, Log Data and/or Location Data whenever You use and/or visit the Website. Whenever You access the Website through Your Mobile Device, We will track and collect Your geo-location data in real-time. You can always choose to disable the geo-location tracking data on Your Mobile Device temporarily. However, this can affect the functionalities available on the Website.


    In addition, whenever You use and/or visit the Website, certain data may also be collected on an automated basis using cookies. Cookies are small files stored on Your computer or mobile device. We use cookies to track user activity to enhance user interface and experience. Most Mobile Devices and internet browsers support the use of cookies; but You may adjust the settings on Your Mobile Device or internet browser to reject several types of certain cookies or certain specific cookies. Your Mobile Device and/or browser would also enable You to delete at any time whatever cookies have previously been stored. However, doing so may affect the functionalities available on the Website.


    We may also use features provided by third parties in order to improve our services and content, including assessing, customising and presenting offers to each User based on interests or visit history. If the User does not want offers to be displayed based on these adjustments, then the User can set it via the browser.



  3. Data collected from third parties

    We may also collect Your Personal Data from third parties (including Our vendors, suppliers, contractors, partners and any others who provide services to Us, who collect Your Personal Data and/or perform functions on Our behalf, or whom We collaborate with). In such conditions, We will only collect Your Personal Data for or in connection with the purposes for which such third parties are engaged or the purposes of Our collaboration with such third parties (as the case may be).


4. HOW WE USE YOUR PERSONAL DATA

We may use Personal Data collected for any of the following purposes as well as for such other purposes as are permitted by Applicable Laws (“Purposes”):

  1. to identify and register You as a User and to create, verify, deactivate or manage Your account on Our Website;
  2. to enable Us to provide services, both services that are already available, services that You request, and services that will be available in the future;
  3. to communicate with You and to send You data in connection with the use of the Website;
  4. to notify You of any updates to the Website or changes to the services available;
  5. to process, follow up, resolve and respond to complaints, problems, questions and suggestions received from You;
  6. to maintain, develop, test, enhance and personalize the Website to meet Your needs and preferences as a User;
  7. to monitor and analyse user activities, behaviour, and demographic data including trends and usage of the various services available on the Website;
  8. to provide services from Our affiliates or partners; and
  9. to send You communications related to campaigns, programs, events, features, launches, and other similar communications that We organize.

We may also use Your Personal Data more generally for the following purposes (although We will in each such case always act reasonably and use no more Personal Data than what is required for the particular purpose):

  1. to undertake associated business processes and functions;
  2. to monitor the usage of the Website and administer, support and improve the performance efficiency, growth, user experience and the functions of the Website;
  3. to provide assistance in relation to and to resolve any technical difficulties or operational problems with the Website or the services;
  4. to generate statistical information and analytics data for the purpose of testing, research, analysis, and collaboration;
  5. to prevent, detect and investigate any prohibited, illegal, unauthorized or fraudulent activities;
  6. to enable Us to comply with all obligations under Applicable Laws, including but not limited to responding to requests, investigations or decree in accordance with regulations, complying with filing, reporting and licensing requirements required by Applicable Laws and conducting audit checks, due diligence and investigation; and
  7. for any other purpose that We notify You of and, where required by Applicable Laws, obtain Your consent to.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may disclose to, allow access to, or share with affiliates and other parties Your Personal Data for any of the following purposes as well as for such other purposes as are permitted by Applicable Laws:

  1. where You are a User, for the purpose of enabling a Service Provider, to perform or deliver a service, including to contact You;
  2. respond to regulatory inquiries, questions, requests, investigations, decisions, and/or reporting, to comply with filing requirements and conditions, as specified in Applicable Laws;
  3. where instructed, requested, required or authorised by the government authorities, for the purpose as specified in the government policy, government regulations or Applicable Laws;
  4. where there is any form of legal proceeding between You and Us, or between You and another party, in connection with, or relating to the services, for the purposes of that legal proceeding;
  5. in an emergency concerning Your health or safety for the purposes of dealing with that emergency;
  6. in situations related to Your health or the public interest, We may share Your Personal Data with authorized government institutions and/or other institutions that may be appointed by the authorized government or have cooperation with Us, for tracking purposes contact, support government initiatives, policies or programs, public health and other purposes as reasonably necessary;
  7. in connection with, any merger, sale of foundation assets, consolidation or restructuring, financing or acquisition of all or a portion of Our entity by or into another foundation/company, for the purposes of such a transaction (even if the transaction is eventually not proceeded with);
  8. to third parties (including Our vendors, suppliers, partners and any others who provide services to Us or You, perform functions on Our behalf, or whom We enter into collaboration with) for or in connection with the purposes for which such third parties are engaged, to perform certain disclosure to the relevant third parties which are technically required for the purposes of Our collaboration with such third parties (as the case may be), which may include allowing such third parties to introduce or offer events or services to You, authenticate You or connect with Your account, or conducting other activities including research, and analysis; and
  9. where We share Personal Data with affiliates, We will do so for the purpose of them helping Us to provide the Website, to operate Our business, or for the purpose of them conducting data processing on Our behalf.

Where it is not necessary for the Personal Data to be associated with You, We will use reasonable endeavours to remove the means by which the Personal Data can be associated with You as an individual before disclosing or sharing such data.


We will not sell or lease Your Personal Data.


Other than as provided for in this Privacy Notice, We may disclose or share Your Personal Data if We notify You or We have obtained Your consent for the disclosure or sharing.

6. DATA RETENTION

Your Personal Data will only be held for as long as it is necessary to fulfill the purpose for which it was collected, during the retention period or for as long as such retention is required or authorised by Applicable Laws. We shall cease to retain Personal Data, or remove the means by which the Personal Data can be associated with You as an individual, as soon as it is reasonable to assume that the purpose for which that Personal Data was collected is no longer being served by retention of Personal Data, there is a request from You to delete Your account, and retention is no longer necessary for legal or business purposes.


We will delete and/or anonymise User Personal Data under Our control when (i) User Personal Data is no longer necessary to fulfill the purpose for which it was collected; (ii) end of the retention period and (iii) storage is no longer necessary for the purpose of compliance with Applicable Laws.


Please note that there is still the possibility that some of Your Personal Data might be retained by the other party, including by the government institutions in some manner. In the event We share Your Personal Data to the authorised government institutions and/or other institutions that may be appointed by the government authorities or have a cooperation with Us, You agree and acknowledge that the retention of Your Personal Data by the relevant institutions will follow their respective policy on data retention.


To the fullest extent permitted by Applicable Laws, You agree to indemnify, defend and release Us from and against any and all claims, losses, liabilities, expenses, damages and costs (including but not limited to legal costs and expenses on a full indemnity basis) resulting directly or indirectly from any unauthorised retention of Your Personal Data.


7. DATA SECURITY

Confidentiality of Your Personal Data is of utmost importance to Us. We will use all reasonable efforts to protect and secure Your Personal Data against access, collection, use or disclosure by unauthorised persons and against unlawful processing, accidental loss, destruction and damage or similar risks. However, because data transmission via the internet is not completely secure, We cannot fully guarantee that Personal Data will not be intercepted, accessed, disclosed, altered or destroyed by unauthorized third parties, due to factors beyond our control. You are responsible for keeping Your account details confidential and You must not share Your account details, including Your password with anyone and You must always maintain and fully responsible for the security of the device that You use.

8. ANONYMOUS DATA

We may create, use, license or disclose Personal Data, provided, however, (i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, and (ii) that has been combined with similar data such that the original data forms a part of a larger data set.

9. YOUR LEGAL RIGHTS

You may have certain rights under Applicable Laws to request Us for access to, correction of and/or deletion of Your Personal Data in Our possession and control. To the extent these rights are available to You under Applicable Laws. You may exercise these rights by contacting Us at the details provided in this Privacy Notice.


We reserve the right to refuse Your requests for access to, correction of and/or deletion of, some or all of Your Personal Data in Our possession or control if permitted or required under any Applicable Laws. This includes circumstances where the Personal Data may contain references to other people or where the request for access or request to correct or delete is for reasons that We consider to be irrelevant, frivolous or far-fetched or indicated to be related to violations of the terms of use or to any activity or violation of the law.


We reserve the right to charge an administrative fee for each access and/or correction request, to the extent it is permissible under the Applicable Laws.

10. UPDATES TO THE PRIVACY NOTICE

We may review and amend this Privacy Notice at Our sole discretion from time to time, to ensure that it is consistent with Our future developments, and/or changes in legal or regulatory requirements. If We decide to amend this Privacy Notice, We will notify You of any such amendments by means of a general notice published on the Website, or otherwise to Your email address set out in Your account. You agree that it is Your responsibility to review this Privacy Notice regularly for the latest information on Our data processing and data protection practices, and that Your continued use of the Website, communications with Us, or access to and use of the services following any amendments to this Privacy Notice will constitute Your acceptance to this Privacy Notice and all of its amendments.

11. HOW TO CONTACT US

If You have any questions or complaints regarding this Privacy Notice or if You wish to exercise Your rights regarding Your Personal Data, please contact the Data Protection and Privacy Office:

Yayasan Anak Bangsa Bisa (GoTo Impact Foundation)

(Data Protection & Privacy Office)

Pasaraya Blok M Gedung B Lt. 6

Jalan Iskandarsyah II No. 2 RT.3/RW.1,

Melawai, Kby. Baru, Kota Jakarta Selatan,

Jakarta 12160

2023 GoTo Impact Foundation