LEAPVERSE PRIVACY POLICY
as of Desember 2021

The following Privacy Policy describes how we, Yayasan Mulia Utama Mandiri (LKP LEAP affiliates, “we”, “us” or “our”) collect, store, use, process, retain, transfer, disclose and protect your Personal Information. This Privacy Policy applies to all users of our applications, websites (leapsurabaya.sch.id), services, or products (“Applications”), unless covered by a separate privacy policy.

Please read this Privacy Policy thoroughly to ensure that you understand our data processing practices. Unless otherwise defined, all capitalized terms used in this Privacy Policy shall have the same meaning ascribed to them in the Terms of Use.

This Privacy Policy includes the following matters:

        1. Personal Information which we collect
        2. The use of Personal Information which we collect
        3. Retention of Personal Information
        4. Access and Correction of Personal Information
        5. Cross Border Data Transfer
        6. Security of your Personal Information
        7. Changes to this Privacy Policy
        8. Acknowledgment and consent
        9. Anonymous Data
        10. How to contact us

PERSONAL INFORMATION WHICH WE COLLECT
We collect information which identifies or can be used to identify, contact, or locate the person or device to whom that information pertains (“Personal Information”). Personal Information includes, but limited to name and email address. 

Information obtained from you or from your mobile device directly
When you register and create an account with us using the Application you have to provide to us certain Personal Information, including your name and  email address 

Information collected whenever you use the Application or visit our website
Whenever you use the Application or visit our website, we may collect certain technical data concerning your usage such as, internet protocol (IP) address, information 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 that you use to access the Application or our website.

Whenever you use the Application or visit our website, certain information may also be collected on an automated basis using cookies. Cookies are small application 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 Application or our website.

THE USE OF PERSONAL INFORMATION WHICH WE COLLECT
We may use Personal Information collected for any of the following purposes as well as for such other purposes as are permitted by applicable law (“Purposes”):

Where you are a user, we may use your Personal Information:

        1. to identify you and to register you as a user and to administer, verify, deactivate, or manage your account as such;
        2. to facilitate or enable any verification as we may in our discretion consider necessary before the service provider provide you with the services or before we register you as a user, including performing Know Your Customer (KYC) and credit scoring;
        3. to communicate with you and to send you information in connection with the use of the Application; 
        4. to notify you of any updates to the Application or changes to the services available; 
        5. to process and respond to enquiries and feedback received from you; 
        6. to maintain, develop, test, enhance and personalize the Application 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 Application; 
        8. to identify you and to register you as a service provider and to administer, manage or verify your Account as such;
        9. to facilitate or enable any verification as we may in our discretion consider necessary before we register you as a service provider, including for KYC and credit scoring;
        10. to enable you to provide services to users;
        11. to provide you with notification and updates on the Application or changes to the manner in which services are to be provided;
        12. to provide you with a report in relation to the Services that you have provided;
        13. to process and respond to feedback from users on the services which you have provided;

RETENTION OF PERSONAL INFORMATION
Your Personal Information will only be held for as long as it is necessary to fulfill the purpose for which it was collected, or for as long as such retention is required or authorized by Applicable Law. We shall cease to retain Personal Information, or remove the means by which the Personal Information can be associated with you as an individual, as soon as it is reasonable to assume that the purpose for which that Personal Information was collected is no longer being served by retention of Personal Information and retention is no longer necessary for legal or business purposes.

We do not encourage the retention of Personal Information by such means and we have no responsibility to you for the same. We shall not be liable for any such retention of your Personal Information. You agree to indemnify, defend and release us, our officers, directors, employees, agents, partners, suppliers, contractors and Affiliates 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 unauthorized retention of your Personal Information.

ACCESS AND CORRECTION OF PERSONAL INFORMATION
Subject to the applicable law, you may request us for access to and/or the correction of your Personal Information in our possession and control, by contacting us at the details provided below.

We reserve the right to refuse your requests for access to, or to correct, some or all of your Personal Information in our possession or control if permitted or required under any applicable law. This may include circumstances where the Personal Information may contain references to other individuals or where the request for access or request to correct is for reasons which we reasonably consider to be trivial, frivolous or vexatious.

CROSS BORDER DATA TRANSFER
When you are using our Application and services in other countries where our Application is also accessible (“Designated Country”), we may transfer your Personal Information from the origin country (“Origin Country”) to the Designated Country in order to enable and ensure smooth customer experience when you are using our Application abroad. In such a case, we will ask for your consent to transfer your Personal Data from the Origin Country to the Designated Country in order to ensure compliance to the applicable laws and regulations.

Your Personal Information may also be stored or processed outside of your country by our personnel who work for us in other countries, or by our third-party service providers, vendors, suppliers, partners, contractors or Affiliates.

We will comply with the applicable laws and regulations and use all reasonable endeavors to ensure that our Affiliates abroad and all such third-party service providers provide a level of protection that is comparable to our commitments under this Privacy Policy.

SECURITY OF YOUR PERSONAL INFORMATION
Confidentiality of your Personal Information is of utmost importance to us. We will use all reasonable efforts to protect and secure your Personal Information against access, collection, use or disclosure by unauthorised persons and against unlawful processing, accidental loss, destruction and damage or similar risks. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, you acknowledge that we cannot guarantee the integrity and accuracy of any Personal Information which you transmit over the Internet, nor guarantee that such Personal Information would 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.

CHANGES TO THIS PRIVACY POLICY
We may review and amend this Privacy Policy 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 Policy, we will notify you of any such amendments by means of a general notice published on the Application and/or website, or otherwise to your e-mail address set out in your account. You agree that it is your responsibility to review this Privacy Policy regularly for the latest information on our data processing and data protection practices, and that your continued use of the Application or website, communications with us, or access to and use of the services following any amendments to this Privacy Policy will constitute your acceptance to this Privacy Policy and all of its amendments.

ACKNOWLEDGMENT AND CONSENT
By accepting the Privacy Policy, you acknowledge that you have read and understood this Privacy Policy and you accept all of its terms. In particular, you agree and consent to us collecting, using, sharing, disclosing, storing, transferring, or otherwise processing your Personal Information in accordance with this Privacy Policy.

In circumstances where you provide us with Personal Information relating to other individuals (such as Personal Information relating to your spouse, family members, friends, or other parties), you represent and warrant that you have obtained such individual’s consent for, and hereby consent on behalf of such individual to, the collection, use, disclosure and processing of his/her Personal Information by us.

You may withdraw your consent to any or all collection, use or disclosure of your Personal Information at any time by giving us reasonable notice in writing using the contact details stated below. 

Depending on the circumstances and the nature of the consent which you are withdrawing, you must understand and acknowledge that after such withdrawal of consent, you may no longer be able to use the Application or services. A withdrawal of consent by you may result in the termination of your account or of your contractual relationship with us, with all accrued rights and obligations remaining fully reserved. Upon receipt of your notice to withdraw consent for any collection, use or disclosure of your Personal Information, we will inform you of the likely consequences of such withdrawal so that you can decide if indeed you wish to withdraw consent.

ANONYMOUS DATA
We may create, use, license or disclose Personal Information, 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. 

THIRD PARTY PLATFORM

The Application and website, may contain links to websites that are operated by third parties. We do not control nor accept liability or responsibility for these websites and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. Please consult the terms and conditions and privacy policies of those third-party websites to find out how they collect and use your Personal Information.

HOW TO CONTACT US
If you have any questions regarding this Privacy Policy or you would like to obtain access to your Personal Information, please contact apps@leapsurabaya.sch.id   

For other questions or complaints, you can contact us via email or telephone at the following contacts : apps@leapsurabaya.sch.id and phone at +62 851 7205 0025.