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This version is made for translation purposes only. In case of any difference between the Indonesian and English versions, the Indonesian will govern all differences, and the English version will be considered to have been amended and adapted to the Indonesian version.

Privacy Policy

 

PT VIDIO DOT COM, a company established by virtue of the law of the Republic of Indonesia, having its office domicile at SCTV Tower, 14th floor, Senayan City, Jl. Asia Afrika Lot.19, Jakarta 10270, Indonesia (“VIDIO”), having and providing over-the-top service via https://www.vidio.com and/or Vidio application (video sharing platform broadcasting the digital content via internet network (“streaming”) on website, m-sites and mobile application, including on the online channel becoming its distribution channel).

 

The definition of VIDIO in this Privacy Policy includes VIDIO affiliates, VIDIO Representatives, i.e. the financial advisors, insurance, law, accounting, or other VIDIO advisors providing the professional services to VIDIO, and the third parties entering into cooperation with VIDIO, i.e. partners, vendors and subcontractors (if required).

 

All capitalized terms not defined otherwise in this Privacy Policy will have meaning same as those in the User Regulation.

 

In maintaining the trust provided by the Users, VIDIO applies the appropriate standards for the protection of the users' personal data as follows:

 

  1. Objective of Privacy Policy
  2. Collection of Personal Data
  3. Payment of and Information on Billing
  4. Data Transfer, Storage and Processing
  5. Disclosure
  6. Limitation of VIDIO’s Responsibility
  7. Security
  8. Changes of Privacy Policy
  9. Contact us

 

  1. OBJECTIVE OF PRIVACY POLICY

1.1         This Privacy Policy explains how VIDIO collects, uses, processes and protects the Personal Data of VIDIO Service Users.            

1.2         This Privacy Policy explains the use of information and/or Personal information provided or collected via site and application, where this Privacy Policy is posted and/or the affiliates’ or third parties’ sites/platforms that are able to provide Platform and/or all features and/or services available on the Platform. VIDIO applies this Privacy Policy in accordance with the law prevailing at the place at which we operate the site and application by complying with this Privacy Policy. VIDIO will send the notification when there is request for additional personal data for certain features or services.            

1.3         The Users are expected to be careful because in VIDIO’s platform there are links to the other platforms that are not owned or controlled by VIDIO, thereby VIDIO has no responsibility for the User providing the personal data to such platform. Please always read the Privacy Policy carefully.            

 

  1. COLLECTION OF PERSONAL DATA

Personal Data is any information allowing VIDIO to identify certain Personal or causes certain Personal to become identifiable based on the information itself or based on the combination with the other information (whether directly or indirectly), and other information related to the Personal by complying with the implementation of the prevailing law on data protection.

2.1         The Data and information provided by the Users to VIDIO may include the name, user name, password, email address, mobile phone number, address and/or location, zip code, account verification, payment and other information related to the transaction on VIDIO’s platform, including interacting with VIDIO’s User Service or participate in the survey or marketing promotion, and the information when the Users choose the language and content preferences, account setting, game play data during the game play event or other information through VIDIO’s platform.            

2.2         Personal Data collected automatically such as User's track record (log) covering but not limited to the device IP address, date and time of access, application feature, duration of websites viewed, application work process and other system activities, type of web browser, and/or site or service site of the third parties used before interacting with the site.

2.3         Personal Data originating from the third parties such as TV or internet service providers, or other streaming media devices providers making VIDIO services are available on the User’s devices; mobile operators or other companies providing services to the Users and collect the payments for VIDIO’s services to be distributed to VIDIO or providing the prepaid promotion for VIDIO’s services; and the voice assistant platform provider allowing the interaction with VIDIO’s Services via voice commands.            

2.4         Personal Data and information from the other sources may cover:

  1. Service providers assisting to determine the location based on User's IP address to adjust VIDIO’s services and other uses in accordance with this Privacy Policy.
  2. Security service providers providing us the information to secure VIDIO’s Services, prevent the fraud, and help us to protect the security of VIDIO’s accounts.
  3. The payment service providers providing us the Payment Information or balance, or updates of such information, based on their relationship with the Users.
  4. Online and offline data providers providing VIDIO the aggregated, interest-based, and interest-related demographic data relating to the online advertisement.
  5. Publicly available sources such as publicly available posts on social media platforms and information made available through the public databases connecting IP addresses to Internet service providers (ISPs).

The Users hereby provide the explicit approval to the acquisition, storage, use, utilization and/or disclosure of the personal data and information submitted by the Users to VIDIO’s Services, including the User’s personal data, conversations on VIDIO’s Services and the Users hereby declare that the approval to the personal data and information is carried out without any duress, in competence, and consciousness condition, where the approval is provided by the Users when creating VIDIO’s account and using VIDIO’s Services continuously (“User’s Consent”).

 

In relation to this User’s Consent, the User hereby declares that all data and information above are VIDIO’s property. To avoid from doubt, the User’s personal data, whether entered into VIDIO’s Services or not included into VIDIO’s Services, are the User’s property as the part of his full personal rights.

 

The User hereby declares that the personal data submitted by the User to VIDIO’s Service (including the documents uploaded and/or provided to VIDIO) are original, authentic, true, accurate, complete, not misleading, up to date, and constitute the personal right of the User and/or he has authority to submit the User’s personal data for submission into VIDIO’s Services.

 

VIDIO protects all information provided by the User when the User uses all VIDIO’s services, including maintaining the confidentiality, integrity, and availability of the personal data it manages.

 

VIDIO shall be entitled from time to time to request for authentication and updating of the User's personal data, thereby the User’s data and information are accurate, complete, and up to date, including temporarily stopping the Service and/or terminating the permanent Service, in case the User does not yet authenticate and update the User's personal data and the User shall be entitled from time to time to update the User's personal data.

 

The User hereby understands that the use of certain features in VIDIO requires further authentication of personal data and complies with VIDIO’s User Regulations as well as certain terms and conditions of features in VIDIO. The User hereby confirms that the User’s Consent is an explicit approval to the acquisition, storage, use, utilization and/or disclosure of personal data submitted (inputted) by the User to VIDIO’s Service and certain features on VIDIO, as well as declares that the provision of the use of such personal data is carried out without any duress, in competence, and consciousness condition.

 

3.         PAYMENT OF AND INFORMATION ON BILLING

When the User purchases the subscription package by using one or more of the payment gateway service providers or any online mobile payment service provider that can be used by VIDIO (including any application stores), the following payment information will be collected: details of credit/debit card (number, card expiry date, CVC code) or other bank account details together with the date, time and amount of transaction payment or equivalent information based on the payment method selected by the User. This Payment Information is stored by VIDIO's payment processor and associated to a User name/ID and the location provided with the payment processor to VIDIO, together with a unique customer ID provided by VIDIO to the payment processor and our payment processor uses this Payment Information to process and facilitate the payment of the User’s subscription fees in order that VIDIO is able to provide the services requested by the Users to access the Platform (in other words to carry out the agreement). VIDIO will send the notification on successful transaction to the User already paying the subscription fee, and it will be stored for internal accounting purpose. For certain Payment Method, the Users shall comply with all terms and conditions of the third party’s payment gateway provider referred to the Platform and/or the third party’s platform, if referred to there. The Users acknowledge be bound by the terms and conditions on third party’s payment gateway and/or third party’s platform in accordance with the Payment Method used for payment of the subscription fees.

If the User pays the third party for the subscription package (for example, an application store, digital wallet, telecommunication service provider) the Payment Information is directly collected and controlled by the third party. But, VIDIO may receive the invoice receipt from the third parties for the purchases of the User’s subscriptions and the receipt will be stored for VIDIO's internal accounting and taxes and to fulfill the obligations based on the prevailing law, audit, claim, legal process and/or investigation.

 

4.         DATA USE, STORAGE, UTILIZATION AND PROCESSING

4.1        Related to the use of Information on Personal Data, VIDIO:            

  1. shall be entitled to use the User’s personal data and information to improve the quality and service at VIDIO in accordance with the provisions in the prevailing legislation and based on the User’s Consent.
  2. shall be entitled to use the general information and use of services already collected for verification of User’s data.
  3. shall be entitled to use the information on transaction to monitor and find out the User's transaction pattern, as well as for administration and investigation or other interests as required by the legislation.

d.         shall be entitled to use and store the information on bank’s name including therein the name and account number, name and/or credit card number to ensure the payment/acceptance by VIDIO’s Users.            

e.         shall be entitled to use the User's personal information entirely whole for know-your-customer (“KYC”), the internal data processing to ensure the service functions technically. The User’s information collected can be used to comply with the prevailing legislation, investigation and dispute resolution, and other illegal activities, including if there is dispute with the third parties.            

f.         shall be entitled to use, utilize, and disclose the User's personal data and information based on the User’s Consent, already provided by the User upon the acquisition of personal data, including but not limited to the following conditions, inter alia:            

i.        obliged and/or requested by the competent institution based on the prevailing law provisions, summon, official order of the Court, and/or official order of the relevant agency or apparatus, including but not limited to the dispute, investigatory, investigation, legal process and settlement process of disputes between VIDIO and the Users, between the Users, and the Users and the other parties as well as other illegal activities;            

ii.        obliged and/or requested by the competent banking, financial institution, and/or third parties based on the official requests and the prevailing law provisions;            

iii.         to process all forms of User’s activities including but not limited to process the transaction, payment verification, product delivery and others;            

iv.         VIDIO may enter into cooperation with the other companies and third parties facilitating or providing assistance in the development of certain applications and services for and/or on behalf of VIDIO, covering: (a) providing the User’s assistance; (b) providing geo-location information; (c) carrying out the services related to Application (including but not limited to the maintenance service, database management, analysis and improvement of Application features; (d) assist VIDIO in analyzing how the Application and Services are used as well as how they are developed; or (e) to assist VIDIO's professional advisors and external auditors, including legal advisors, financial advisors, and consultants. These third parties only have access to the User’s Personal Information to carry out these tasks for and/or on behalf of VIDIO and contractually bound to not disclose or use such Personal Information for any other purpose;            

4.2        VIDIO shall be entitled to use, store, utilize and disclose the personal data based on the User’s Consent already provided by the User upon the acquisition of the personal data to:            

a.        provide Third Party’s Services and/or Offer, for example (i) for the purposes related to the payment, billing, activation, provision, maintenance, support, problem solving, dispute resolution, deactivation, replacement, improvement or renewal of Service; (ii) to better understand, analyze, and predict the User’s preferences and interest, and combine the information with the other information to adjust the User’s experience; (iii) to ensure the Service functions technically as referred to above and to assist to identify and solve the problems; (iv) to facilitate the User’s access and the use of Services and/or the Third Party’s Offer; (v) to send the subscription Offer, messages and posting in the Service on behalf of the Channel administrator or Official Account; (vi) to combine the information with the information obtained from the other sources (including the Third Party’s Offer) in relation to the Service provision; (vii) to comply with or enforce the Notification applicable to the Service; (viii) to manage or respond to User’s question;            

b.         develop the new Services and improve the existing Services and provide information to the Users about the third party’s content or relevant products, service and software including to communicate with the Users about various ways they use, for example to provide or send to the Users: (i) the improvement or update, or notification regarding upgrade or update, of the Services or third party’s content or relevant product, service and software; (ii) notification on upcoming promotion, contest, offer and event; (iii) personal information, survey, marketing material, advertisement or adjusted content.            

c.         collect, use and disclose for promotion and advertisement activities covering but not limited to the advertisement identifier, including those provided by the other software platform, or similar identifier, to facilitate VIDIO in carrying out the analytic or provision of promotion content or other information that may be relevant to the Users;            

d.         manage and develop VIDIO's business and operation, for example: (i) to detect, monitor, investigate, reduce or prevent the fraud and technical or security issues or to protect the property of VIDIO; (ii) to allow the business continuity and disaster recovery operation; (iii) to obtain the legal services, to seek for legal advice and/or to enforce VIDIO's legal right or the legal rights of other members of VIDIO; (iv) for statistical purpose;            

e.         comply with the legal and regulation requirements and to respond to emergency situation, for example: (i) to respond to the court’s order, summon or other legal request or other law enforcement or legal process; (ii) to provide the emergency assistance in situations that may threaten your or others’ life or physical safety; or            

f.         VIDIO's internal interest for business, product, quality, and service development including promotion, study, research activities, and VIDIO’s cooperation with the other third parties;            

g.         the interests of VIDIO, VIDIO’s affiliates, and group companies, for business, product, quality and service development including the promotion, study, research activities and VIDIO’s cooperation with the other third parties;            

h.         VIDIO's interest to fulfill the objective of Transaction in favor of VIDIO, including in terms of sale of all or part of VIDIO's assets including any purchase, sale, lease, merger or amalgamation or acquisition, disposal or financing of VIDIO, VIDIO’s affiliates, and group companies; and            

i.         other objectives addressed from time to time by VIDIO to the Users, as well as permitted or required by the prevailing law and regulation.            

4.3         The objective of use and processing of the User's Personal Data for VIDIO are as follows:            

  1. to fulfill the objective of Service, the objective of this Privacy Policy, the objective of the prevailing legislation, including to process, transfer, and/or store the Users’ data and information, both within and outside the territory of the Republic of Indonesia, by taking into account the regulation, including the legislation and Privacy Policy in the country where the Users’ data and information are processed, transferred, and/or stored.
  2. to fulfill the objective of Service, the objective of this Privacy Policy, the objective of the prevailing legislation and law in terms of data utilization and processing. In this case, VIDIO, VIDIO’s affiliates, group companies, covering VIDIO’s representatives, and other third parties entering into cooperation with VIDIO through the agreement and contain the binding confidentiality clauses.
  3. to fulfill the objective of transaction in favor of VIDIO, including in case of sale of all or parts of VIDIO's assets including any purchase, sale, lease, merger or amalgamation or acquisition, disposal or financing of VIDIO, VIDIO’s affiliates, and group companies.
  4. data utilization and processing, including data transmission, in accordance with the objective of this Privacy Policy will apply the security reasonably, in accordance with the prevailing legislation and law, including to provide the encryption on the utilization and processing of such data.

4.4         The User is able to exercise certain control and choice regarding the collection, use and provision of his Personal Information and Data in accordance with the prevailing law, control and choices, i.e. may cover:        

  1. may access several User’s Personal Information and Data through the ‘Profile' part in the platform after successful login. The User shall be responsible for providing the accurate Personal Information and Data to VIDIO and keeping the up to date of Personal Information and Data.
  2. may ask us to correct the Personal Information about you that is inaccurate or incomplete by submitting electronic-mail to us to VIDIO's customer service e-mail address.

4.5         VIDIO keeps the User’s Personal Information and Data as long as required to provide Service and in accordance with the legal processing basis and to fulfill the legal obligations of the Republic of Indonesia. Especially, when determining how long VIDIO keeps the personal data, the calculation of how long the Personal Information and Data is required to:            

a.         Maintain the business records for analysis, tax and/or audit;            

b.         Comply with the requirements of legal notes saving;            

c.         Defend or file any existing or potential lawsuits;            

d.         Legitimate business objectives; and            

e.        Handle the complaints on any Platform/services available on the Platform.            

4.6         For the data collected by VIDIO, and the process based on the permit or approval obtained from the User, the User is able to withdraw the approval at any time, by sending the electronic mail to VIDIO. VIDIO will review the request and may ask the User to verify the User’s identity. In the case where the User approves to provide exact location based on GPS data, the User may at any time withdraw the approval by non-activating the location permit in the setting menu on the User's device. If requiring the assistance to withdraw the User’s permit previously provided, please contact us by using the information provided at the end of this Privacy Policy.            

4.7         The Users shall have right based on the law to decline the use of Personal Information and Data in relation to certain types of processing, including the processing for direct marketing and profiling, the Users may file the objection by changing his preferences, turning off the cookies as described in the Policy on Cookies or by contacting us. If the User desires to stop or limit the processing of the Personal Information and Data in relation to the personalized content or interest-based advertisement, then, unless the platform allows the User to choose the available preference, the User shall stop the use of platform and VIDIO may arrange to cancel his subscription. If the User has prepared the subscription through Apple iTunes or other third party’s platform, then the method of unsubscribing from the Apple iTunes platform or other third party’s platforms shall be in accordance with the process applied to ensure that the User is not continuously billed by Apple or other third party’s platform. In addition, in case of Apple iTunes or other third party’s platform, you shall file the objection to the processing of User's subscription data/personal data on Apple iTunes platform or other third party’s platform in accordance with the applicable process.            

4.8         VIDIO may transfer the User’s Personal Information and Data to VIDIO’s affiliate platform or service providers or third party’s recipients to whom VIDIO provides the technology and hosting services, at the location for the objective explained in this Privacy Policy. Therefore, by approving this Privacy Policy, the User shall also approve to transfer the Personal Information and Data to VIDIO’s affiliate platform or service provider or third party recipient at such location. Wherever the User’s Personal Information and Data is transferred, stored or processed by VIDIO or VIDIO's affiliate platform or service provider, VIDIO will take any reasonable measures to protect the privacy of the User’s Personal Information and Data.            

 

5.                 DISCLOSURE

5.1         With the User’s Consent, VIDIO shall be entitled to disclose the User’s Personal Information and Data with certain objectives and requirements as follows:            

  1. For the marketing, analytic, research, communication, advertisement, IT infrastructure and service, technology or software providers, payment processing, User assistance service and other services in cooperation with VIDIO or assisting VIDIO to provide services to the Users or provide software permit to VIDIO included in VIDIO’s application(s) to provide, support or improve VIDIO’s Services and allow VIDIO to analyze VIDIO's service and marketing programs.
  2. For promotion or joint program that will require VIDIO to share the User’s information with the third parties in supporting the User’s participation. In carrying out this type of promotion, we may share the User’s names and other information in relation to the fulfillment of incentive. Please note that these third parties shall be responsible for their own privacy practices.
  3. If there is processing of personal information and data, transfer of local and interstate data.
  4. If VIDIO is reasonably sure that such disclosure is required to (a) fulfill any prevailing request of the law, regulation, legal process or government, (b) enforce the prevailing provisions on use, including investigation to potential breach therein, (c) detect, prevent, or handle the illegal activities or suspected illegal activities (including fraudulent payment), security issues or technical issues, or (d) protect the right, property or safety of VIDIO, VIDIO’s users, or the public from any losses as required or permitted by the law.
  5. If there is business transfer, such as merger or acquisition by the other company or in case of business reorganization or restructuring.

   

5.2        In disclosing the information:            

a.        VIDIO may inform several personal information of the User thereby the information becomes the information that cannot identify the User entirely (aggregate/anonymous data) addressed to the third parties used for the application development, database management, analysis or service improvement, promotion and advertisement;

b.         VIDIO may also combine the User’s Personal Information and the other information in such a way thereby the information is no longer associated to the User, then discloses the combined information to third parties; and            

c.         VIDIO may also combine the User’s Personal Information and the other information in such a way thereby the information is no longer associated to the User, then discloses the combined information to the third parties;

 

6.         LIMITATION OF VIDIO'S RESPONSIBILITY

6.1         The User shall be responsible for security and breach mitigation of VIDIO’s account of the User itself, such as applying the appropriate security, restricting the access, creating the strong password, maintaining password, maintaining one-time password (“OTP”).            

6.2         VIDIO shall not be responsible for the exchange and provision of the Users’ personal data and information carried out by the Users themselves, including those carried out between the Users. This provision shall include any and all User’s negligence resulting in the User’s data leakage.

6.3         VIDIO shall be responsible for VIDIO’s Services, including the protection and secrecy of the personal data, including notifying the Users in case of failure in personal data protection through at least the Users’ e-mail registered on VIDIO’s Services. In case of data leakage, the party responsible to inform the User related to the failure in data protection shall be the party or institution where the data is processed based on this Privacy Policy.

6.4         VIDIO shall not be responsible for the genuineness, authenticity, correctness, accuracy, completeness of the personal data entered by the User into VIDIO’s Service.

6.5         By issuing the User’s Consent, the User waives the rights to claim, loss, demand and suit potentially occurring for acquisition, storage, use, utilization and/or disclosure of data, including the personal data, in VIDIO’s Service.

6.6        In case the User is a minor, VIDIO shall not be responsible for the input of the child User’s personal data and recommends that the parent/guardian of the child monitors the child's internet usage, thereby the provision of the child User's personal data is provided and/or under the supervision of the parent/guardian as the competent party.            

6.7        VIDIO shall not be responsible for any data leakage occurring as the consequence of and/or occurring during the Force Majeure. The Force Majeure shall cover, inter alia (i) strike, company disclosure and other industrial acts; (ii) riot, insurrection, invasion, terrorist attack or threat, war (whether declared or not) or threat of war preparation; (iii) fire, explosion, storm, flood, earthquake, epidemic or other natural disaster; (iv) unavailability or disruption of telecommunication, informatics and/or electricity networks; (v) there is Service failure caused by the third party occurring beyond VIDIO's authority; (vi) malfunction of the banking system and/or network, (vii) act, judgment, law, regulation or restriction issued by the government. In case of Force Majeure, VIDIO will notify the User within not later than 14 (fourteen) Calendar Days after the Force Majeure and do its best by commercial capability to fulfill VIDIO's obligations based on this Privacy Policy.

 

7.                 SECURITY

7.1        VIDIO will continuously apply and update the administrative, technical and physical security measures to assist to protect the User’s Personal information and Data from unauthorized access, loss, damage or alteration. Several of protections we use to protect the User’s Personal Information and Data such as firewall and data encryption, and information access control. These measures are designed to provide the level of security appropriate to the risks in processing the User’s Personal Information and Data. If the User knows or has reason to believe that the User’s account credential has been lost, stolen, altered or compromised or in case of unauthorized use or suspected unauthorized use of the User's account, please contact VIDIO (see the information below).            

7.2         VIDIO uses commercially reasonable industry standard security practices and procedures designed to help to protect the User’s Personal Information and Data in order to be safe and secure. But, there is no perfect or impenetrable security measures, VIDIO cannot guarantee the data security since every transmission is the User’s risk. VIDIO will always do its best to protect the User’s Personal information and Data and ensure on reasonable basis that every person employed by VIDIO complies with the security standard thereby the protection of the User’s Personal Data is always maintained.            

 

8.         CHANGE OF PRIVACY POLICY

This Privacy Policy may be subjected to change from time to time. VIDIO shall be entitled to update this Privacy Policy to keep it relevant and up to date with the change of technology, the prevailing law, evolving business practice and the User’s needs. VIDIO will provide the most recent update date, if any changes are made to this Privacy Policy. VIDIO appeals to the Users to periodically review this Privacy Policy in order to remain be informed about how VIDIO manages your personal data and information. By using the Service, the User is considered to issue the explicit approval to the Privacy Policy and by continuing to use the Service after the Privacy Policy, the User is considered to have approved to the updated Privacy Policy. If the User disagrees with the renewal, the User may stop using VIDIO’s service by canceling the subscription or deleting the User’s account.

 

9.         CONTACT US

VIDIO complies with all prevailing legislation and the government policy of the Republic of Indonesia, including those regulating the electronic information and transaction, electronic system administration, and protection of User’s personal data; including all implementing regulations and amendments to the regulations regulating and protecting the use of important data and information for the Users. If requiring further information or explanation regarding the use and/or processing of the users' personal data, please contact us via e-mail at info@vidio.com .

 

This Privacy Policy forms an integral and inseparable part of VIDIO’s User Regulation.

 

Latest update as per October 2020