This Data Privacy Policy (also referred to as Policy or Privacy Notice) contains information on how PT. Salvus Prima Perkasa (“Salvus Health”) collects, uses, processes and discloses the User’s Personal Data in connection with the access to and/or use of the online platforms of Salvus Health including, but not limited to, the mobile application, website, and social media accounts (collectively the “Sites” or “Site”). It shall be the sole responsibility of the User to fully read and understand this Policy in accessing the Site or Sites and/or using the Site Services. The User shall be conclusively deemed to have agreed to this Policy and shall be deemed to have given consent to the collection, use, processing, and disclosure by Salvus Health of Personal Data by a.) clicking “Yes” on the Policy pop-up or any web form referring to this Policy on any of the Salvus Health Site or Sites, b.) submitting Personal Data to Salvus Health when registering for a Salvus Health Account, c.) accessing the Salvus Health Site or Sites, or d.) using the Salvus Health Site Services. If User provides Salvus Health Personal Data relating to a third party, User shall be responsible for the required consent of the third party to provide Salvus Health their Personal Data for the applicable purpose/s.
1. DEFINITIONS
“Salvus Health Account” refers to the arrangement in which Salvus Health grants the User the right to access and use the Site or Sites and Site Services upon compliance by the User of Salvus Health requirements. “Personal Data” means any data, whether true or not, which is (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as “personal data” or “personal information” under any applicable Data Protection Laws. Examples of Personal Data that Salvus Health may collect include the User’s name, contact details, email address, birthday, network and device data (including IP address and device or advertising identifiers). “Site or Sites” refers to the online platforms such as the mobile application, website, and social media accounts owned and maintained by Salvus Health. “Site Services” refers to the hosting and maintenance of the Site or Sites by Salvus Health. “User” refers to any person or entity that accesses and/or uses the Site or Sites.
2. COLLECTION OF PERSONAL DATA
When accessing and/or using the Site or Sites, Salvus Health may ask Users to provide Personal Data which may include, but is not limited to, the User’s name, birthday, physical address, email address, phone number. Salvus Health may also collect information on how the Site or Sites are accessed and used ("Usage Data"). This Usage Data may include information such as the User’s computer's Internet Protocol (IP) address, browser type, browser version, the areas of the Site or Sites that Users visit, the time and date of the visit, the time spent on those Site areas, unique device identifiers and other similar data. Salvus Health may use cookies and similar tracking technologies to track the activity on the Site or Sites. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to a User’s browser from a website and stored on the User’s device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse Site or Sites activity and performance.
Users can instruct their browser to refuse all cookies or to indicate when a cookie is being sent. However, if Users do not accept cookies, such Users may not be able to use some portions of the Site or Sites and Site Services. Salvus Health, on its own, does not usually collect User’s credit card details, which are collected, processed and stored directly by Salvus Health third-party payment processors pursuant to their terms of use and privacy policies. None of the User’s credit card details or payment information are stored with Salvus Health.
3. USE OF PERSONAL DATA
Salvus Health may use and disclose Personal Data for purposes necessary to maintain the Site or Sites and provide Users the Site Services, including to: a.) register and maintain Salvus Health Account, b.) deliver or perform the Site Services, c.) process and/or collect payment for Salvus Health fees, fees of Salvus Health business partners, and other related fees and charges, d.) communicate with User regarding queries, requests and feedback as well as material changes to the Site or Sites, Site Services, the Terms of Use, this Policy or other terms and conditions, e.) personalise and improve User experience in using the Site or Sites, f.) monitor and enforce compliance with the Terms of Use, including dispute resolution, g.) comply with internal risk controls, the terms of access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors, or any applicable law h.) ensure Salvus Health Site or Sites function properly and to improve their performance, by carrying out activities such as debugging and statistical analysis, i.) send Users marketing communications in relation to Salvus Health Site or Sites and in relation to the sales, products, services or promotions of business partners, j.) deliver ads which may be of interest to Users on the Site or Sites or other websites, apps or online platforms, k.) invite Users to Salvus Health events, l.) process User participation in Salvus Health and Salvus Health business partners’ promotions and initiatives, m.) conduct market and customer research, analysis or tracking, n.) manage the administrative and business operations of Salvus Health, and o.) for other purposes which are reasonably related to the foregoing.
Salvus Health will make reasonable efforts to ensure Personal Data that it will use or disclose to another organization is accurate and complete. However, Users should update Salvus Health of any changes in the Personal Data. Salvus Health will not be responsible for relying on inaccurate or incomplete Personal Data if Users have not updated Salvus Health of changes.
4. STORAGE, RETENTION, AND SECURITY OF PERSONAL DATA
The Personal Data is stored and processed in Indonesia. If the User is located outside Indonesia and chooses to provide Personal Data to Salvus Health, the User is informed that Personal Information are stored and processed on computers located outside of User’s state, province, country or other governmental jurisdiction where the data protection laws may differ from those of User’s jurisdiction.
Salvus Health will not retain Personal Data for longer than is necessary and will take reasonable steps to destroy or permanently de-identify Personal Data. Salvus Health will take all the steps reasonably necessary to ensure that Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of Personal Data will take place to an organisation or a country unless there are adequate controls in place. In the event that Salvus Health becomes aware of a security breach which Salvus Health may believe has resulted or may result in the unauthorized access, use, or disclosure of Personal Data, Salvus Health will promptly investigate the matter and notify the User of such breach. However, Salvus Health will not be responsible for any unauthorized use of Personal Data by third parties which is attributable to factors beyond the control of Salvus Health.
5. SHARING AND DISCLOSURE OF PERSONAL DATA
Pursuant to the stated uses of Personal Data, Salvus Health may disclose User’s Personal Data to:
a. Employees, consultants, and other personnel;
b. Other Users of the Site or Sites;
c. Payment processors, who process User’s payment on the Site or Sites;
d. Logistics providers, such as courier services;
e. Business partners in connection with the processing of any promotion, event or service organised by Salvus Health;
f. Professional advisers and consultants;
g. Agents, contractors or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimization, information technology, telecommunications, security or other relevant services which requires their collection, use or disclosure of Personal Data; and
h. Any other party whom a User authorizes us to disclose Personal Data to.
Under certain circumstances, Salvus Health may be required to disclose Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Salvus Health may disclose Personal Data in the good faith belief that such action is necessary to:
a. To comply with a legal obligation;
b. To protect and defend the rights or property of Salvus Health;
c. To prevent or investigate possible wrongdoing in connection with the use of the Site or Sites;
d. To protect the personal safety of Users of the Site or Sites or the public; and
e. To protect against legal liability.
6. ACCESS TO AND CORRECTION OF PERSONAL DATA
Users may access or correct their name, birthday, and addresses by logging in the Salvus Health Account on the Site or Sites and clicking the “Edit” button under each relevant field.
For Personal Data that cannot be corrected by Users by logging in to their Salvus Health Account on the Site or Sites, the User may request to access to and correct such Personal Data by emailing our Data Protection Officer at cs@salvus.co.id
Salvus Health may need to request additional information from the User to confirm User’s identity before providing the access or making the correction. Salvus Health will do its best to respond to Personal Data access and correction requests within 30 days. Where we are unable to meet this timeline, we will update you with the soonest possible time within we can provide the information or make the correction. Please note that certain types of Personal Data access and correction requests may be exempt under Applicable Laws. Note that we may charge you a reasonable fee for the handling and processing your Personal Data access request.
We will promptly send the corrected Personal Data to every other person or entity to which such Personal Data was disclosed by Salvus Health within the year before the date of the correction, unless such person or entity does not need the corrected Personal Data for any legal or business purpose.
Subject to obtaining User’s consent, Salvus Health may send the corrected Personal Data only to specific organisations to which the Personal Data was disclosed by Salvus Health within a year before the date the correction was made.
7. WITHDRAWAL OF CONSENT
User may withdraw consent for the collection, use and/or disclosure of any Personal Data by Salvus Health by submitting a written request through email to our Data Protection Officer via email at cs@salvus.co.id
Note that, depending on the nature of the consent withdrawal, Salvus Health may not be able to continue to allow User access to the Site or Sites and/or use of Site Services. Salvus Health will process such a request within a reasonable time from receiving notice from User of the withdrawal of consent. Once the processing is complete, Salvus Health will no longer collect, use and/or disclose Personal Data, except to the extent Salvus Health needs to retain Personal Data for compliance, regulatory or other legal purposes.
User may withdraw consent for Salvus Health to send sales, marketing or promotional information by clicking on the Unsubscribe link in the promotional emails sending an email at the email address provided below. Once Salvus Health receives notification that User wishes to withdraw consent for receiving marketing or promotional materials or communications, it may take up to thirty (30) days for the withdrawal to be reflected in Salvus Health systems. Therefore, User may still receive marketing or promotional materials or communications during this period.
8. CONTACTING SALVUS HEALTH
For any questions relating to Personal Data or about this Policy, or if a User has a complaint regarding the collection, use or handling of Personal Data by Salvus Health, a User may contact our Data Protection Officer via one of the following methods:
Email address: cs@salvus.co.id
Office address: Jl. Tomang Raya No. 47F Jakarta 11440, Indonesia
9. DATA POLICY UPDATES
Salvus Health may update this Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. User agrees to be bound by the prevailing terms of the Policy as updated from time to time.
10. GOVERNING LAW
This Policy and use of the Site or Sites and/or Site Services shall be governed in all respects by the laws of Indonesia.