LEGAL STATEMENT
Welcome to the "SWAP" platform service!
Your trust is very valuable to us. Personal information is very important, we will do our best to take appropriate security protection measures as stated in applicable laws and regulations.
So the definitions in this "Legal Statement and Privacy Policy" (hereinafter "this policy" or "this privacy policy") are as follows:
When using the services provided by us, you agree that we collect, store, use, disclose and protect your personal information in accordance with the privacy policy published on our platform. Through this privacy policy, we clearly inform you how we handle your personal information. We recommend that you read this privacy policy in full to help better protect your privacy.
According to the requirements of relevant laws and regulations, if network products and services have the function of collecting user information, the provider must declare and obtain the consent of the user. Through this privacy policy, we tell you clearly about the purpose, methods, query and correction of information, the consequences of refusing to provide information, as well as the scope of collection and use of users' personal information.
Before using our platform products or services, please read and fully understand this policy. Use the related products or services after confirming your full understanding and agreement. If you do not agree with any content of this privacy policy, please immediately stop using our platform services. When you use any services provided by our platform, this means you have agreed to us collecting, using and protecting your personal information legally in accordance with this privacy policy. If you have questions, comments or suggestions about the content of this policy, you can contact us by telephone customer service. Customer service hotline: 088808700800, service hours 9 am to 6 pm WIB, Monday to Friday, except holidays.
Privacy Policy
This section of the privacy policy will help you to understand the following:
How we collect your information
How we use your information
How we share, transfer and disclose your information
How we use cookies and similar technologies
How we store your information
How we protect your personal information
Protection of minors
How you manage personal information
How your personal information is transferred globally
Revisions and updates to this privacy policy
Providing better and more personalized service to users is our main goal. So we can provide you with more effective and convenient service. This privacy policy applies to all services provided by our platform, such as when you visit our web platform or log in to the relevant client to use the services provided. This privacy policy also applies in the absence of an independent privacy policy for our web platform, server or relevant client login.
It should be emphasized that this privacy policy does not apply to services provided to you by other third parties. For example, when third parties on our platform (which are on our platform) provide services to you such as third party payments, then personal information provided to those third parties does not apply to this privacy policy. This does not apply if there is a law that clearly stipulates it, so we are not responsible for your use of information provided to third parties.
We strictly comply with applicable laws and regulations. As well as collecting, processing or using your personal information correctly based on the principles of validity, fairness, honesty, credibility and other necessary legal principles.
How we collect your information , to help you become our member and provide better and more personalized services, such as remote motorbikes, top up kilometers, and battery replacement, we will collect the following information according to the services you provide use:
We provide third party account login function. If a user chooses Google or Facebook to log in, we need to collect and store the user's Google and Facebook IDs as login credentials;
Information that you provide to us , before using the "SWAP" platform services, you need to create an account on the "SWAP" platform by filling in personal information . You need to fill in your mobile number, verification code, name and email address, and create a password. If you refuse to fill in the data, the "SWAP" platform will not be able to create an account and provide services for you.
When you use our platform, you need to fill in and provide the required data according to the service content. Such data may include your name, gender, identity information, license plate number, telephone number, email address, home address, and emergency contacts including name, address, and telephone number (to protect your personal and property security). If you do not use a particular service, you do not need to provide relevant information.
You must register your license plate number via the "SWAP" platform first to be able to use power exchange, check electric motor status information and data services. If you refuse to register the license plate number, then the “SWAP” platform will not be able to provide you with such services.
Your information stored when using our platform services . According to relevant national legal requirements, we will collect content information (including but not limited to comments, contents and others) and behavior information (including but not limited to power exchange reservation records , electric motor driving, re-top up and other user behavior) provided by you when using our services. For example, when you provide information on our platform, our customer service team will contact you and provide you with relevant information. This also applies when you provide information in the form of a questionnaire (anonymous questionnaire or registered user questionnaire) or any other form.
Information Collected While You Use This Service To provide and optimize the service, we will receive and record relevant information from browsers, computers, mobile devices and other devices in accordance with the permissions you provide, including:
Device information (such as device model, operating system version, device settings, unique device identification code, and other software and hardware feature information, etc.);
Location information (such as obtained from IP addresses, GPS, Bluetooth signal access points, WIFI, Internet of Things, Base Transceiver Station, etc.);
Travel plan information: "SWAP" will record departure, arrival, route, duration and travel distance information from user behavior via mobile phone. "SWAP" collects the above information based on legal and regulatory requirements, for the need to protect your personal and property security, and the need to handle user concerns in accordance with the rules on the platform. Geographic location information is sensitive personal information, so "SWAP" will do its best to protect the security of such information. If you refuse to provide this information, then you cannot use the above functions .
Data History Information : When you use products or services provided by our website or clients, we will automatically collect detailed usage data from our services as stored web history.
We may associate information collected from your various devices so that we can provide consistent service. Please note that individual device information, historical information, etc. cannot identify specific individuals. If we combine this type of non-personal information with other information to identify a specific person or use it in combination with personal information, then during this combined use, this type of non-personal information will be treated as personal information, unless by your authorization or otherwise provided by law -laws and regulations, we will anonymize and de-identify such personal information.
Order information: In order to display your account order information (such as purchasing power exchange fees, etc.), we will collect order information and consumption records used during the use of the service so that you can view purchase records and progress in transaction management.
Customer service information: When you contact us, communication data (chat or telephone call content, contact details and history) will be stored by us so that we can contact and assist you in solving problems, or record problems regarding the plan and outcome of the problem.
Recording information: The Swap Station may be equipped with equipment such as a video recorder. You may be recorded during the power exchange process at the Swap Station. "SWAP" maintains such records in accordance with applicable legal and regulatory requirements. These recordings can be used to resolve issues with users or security incidents, as well as to protect the security of SWAP assets, as well as verify facts and handle complaints.
In addition to the information above, we may also collect other information about you (including information when you interact with our affiliates and partners) for the reasonable purposes of providing and improving the quality of services.
Information from third parties , affiliates and our partners may provide your personal information to us by following applicable laws, under the premise of regulations or agreements with you as a user. This aims to provide you with a better, more personalized service, as well as providing you with internet fraud-free services.
How we use your information We will collect and use your personal information for the following purposes described in this policy:
Help you become our member or become a user who can engage in activities such as renting batteries, providing comments and other interactive activities.
Providing services: providing you with various products and services that can be used (such as: electricity exchange costs, GPS positioning of electric motors, etc.), including design, maintenance and improvement services for these services.
We would like to recommend content products and services that may be of interest to you (including but not limited to sending product and service information, content recommendation information, marketing information, cooperation information, or personalized promotions through third party promotion systems) as well as displaying various information from our affiliates and partners with your consent, so they can send you information about their products and services. If you do not wish to receive the above information, you can unsubscribe via the unsubscribe function .
Risk identification: We may use your personal information to prevent, detect, investigate fraud and security harm, illegal acts that violate our and our affiliates' agreements, policies and rules. Examples include abnormal member account activity, multi-terminal logins, abnormal data usage, abnormal refund requests, transfers of cheap subscription packages, and others. These things are done to protect the rights of you and our other users, or us as a company and its affiliates.
Personalized services: In order to provide you with more personalized services, we may combine personal information from one service with other services. For example, by using, sharing, disclosing this information to meet needs on a wider social scale.
Surveys and activities: Allows you to participate in surveys about our products and services, as well as promotions and sweepstakes.
- Other uses with your permission.
How we share and disclose your information , transfer and disclose . We have an obligation to maintain confidentiality and will not share your personal information with other third parties, except in the following cases:
Sharing with your own consent, authorization or choice. After obtaining your official authorization or consent, we will share your personal information with other companies, organizations and individuals. For example, if we entrust a third party to provide you with products or services (such as user activity, sending lottery prizes, point redemption rewards), then we will share the above information with the third party after obtaining your consent. If you refuse to provide Information, then we will not be able to complete the relevant services. Unless you voluntarily or officially consent, we will share and disclose your sensitive personal information publicly.
Sharing and disclosure under legal conditions.
In the need for dispute resolution, litigation, or as required by administrative and judicial authorities in accordance with law, we may share your personal information externally in accordance with applicable laws and regulations. For example, if we determine that you have violated laws and regulations or seriously violated the relevant agreement rules of our platform, or to protect the personal property of our platform website and its affiliated users or the public from violations, And if we have already taken steps- steps in accordance with the platform rules, Then we will use the relevant agreement Rules of the platform to disclose personal information about you.
Sharing your personal information with our affiliates, and affiliated companies:
To make it easier for us to provide services to you under an affiliated account, and to recommend information that may be of interest to you or protect the personal safety of our affiliated companies or other users or public property, your personal information will be shared with our affiliates. We will only share personal information that is necessary (such as facilitating you to log into our account and use our affiliated companies' products or services) to comply with the purposes of this privacy policy. We will ask for your formal permission again to share your sensitive personal information, if the affiliated company changes the purposes for which it uses and processes personal information.
Share with official partners.
We will entrust authorized partners to provide you with certain services or perform functions on our behalf. We will only share your information for lawful, appropriate, specific, clear and necessary purposes. Authorized partners only obtain this information to carry out their duties, and cannot use it for any other purpose. Our official partners include the following types:
Suppliers, service providers and other partners
We send information to suppliers, service providers and other partners (such as hardware manufacturers, telecommunications operators, and others) who support our business. This support includes providing infrastructure technical services, analyzing service usage and effectiveness, providing customer service, facilitating payments, or conducting academic research and surveys. For companies, organizations and individuals with whom we share personal information, we will sign strict data protection agreements with them, then require them to process personal information in accordance with our instructions and take all other relevant confidentiality and security measures in accordance with this privacy policy. If we share your sensitive personal information or authorize partners to change the purposes for which they use and process personal information, we will ask for your authorization again.
Helps in handling disputes
If you are a qualified intellectual property complainant and have filed a complaint, then you must disclose it to the respondent at the respondent's request so that both parties can address any potential rights disputes. Only by sharing your personal information can we provide the services you need, and resolve disputes between you and others. We will provide the necessary information to the institutions mentioned above, such as the contact information of the complained user, as necessary to facilitate the resolution of transaction disputes. Our platform is only liable to appropriate laws if the law clearly provides so.
Transfer , we will not transfer your personal information to any company, organization or individual, except as follows:
Transfer with formal consent: After obtaining your formal consent, we will transfer your personal information to another party;
In the event of a merger, acquisition or bankruptcy liquidation of our platform service providers, or other situations involving a merger, acquisition or bankruptcy liquidation, and if this involves the transfer of personal information, then we will ask the new company or organization that holds your personal information to continue to comply with this policy. If not, then we will ask companies, organizations and individuals to ask you for Return authorization.
Exceptions to prior authorization obtained when sharing, transferring and disclosing personal information.
In the following situations, sharing, transferring and publicly disclosing your personal information does not require your consent:
Related to national security and national defense;
Related to safety, health and the main interests of society;
Related to criminal investigations, prosecutions, trials, and execution of decisions, and others.
To protect you and others' persons, property, and other important legal rights and interests, but it is difficult to obtain your consent;
Personal information that you disclose to the public;
Collection of personal information from publicly disclosed information, such as legal news reports, government disclosures and other channels.
According to the law, if personal information that has been identified to be shared, transferred, makes it impossible for the recipient of the data to recover and re-identify the personal information, then it is not an external sharing, transfer and public disclosure of personal information. We do not need to notify you separately and obtain your consent in storing and processing data. If you do not agree to provide your personal information to third parties in accordance with the above clause, then immediately stop using our platform services. If you use one of the services provided by our platform without expressing disagreement, then you are deemed to have agreed to provide personal information to third parties in accordance with the clause above.
How we use cookies and similar technologies
Cookies
In order to make it easier for you to visit the platform website or use the services provided by our platform, and to make it easier to repeat information registration steps and to ensure the security of your account, we can recognize your identity through a small data file. These data files may be cookies, flash cookies, or other local storage provided by your browser or associated applications (collectively, "cookies").
Please understand that some of our services are only possible through the use of "cookies". If your browser or additional browser services provide permission, then you can modify our level of acceptance or rejection of cookies. However, under certain circumstances this action may affect your security access to our platform website and in the use of related services provided by our platform.
Web pages often contain multiple electronic images (called “single-pixel GIF files” or “web beacons”). The use of web beacons can help websites count users browsing the web, collect activity information, or access certain cookies. Such as the addresses you have visited and have visited, the duration of your access to the page, your browsing environment, display settings, and others.
We also need to save the Firebase Installation ID of the user's device. Notification messages to users to remind users that the battery is too low and needs to be replaced , etc.
Website beacons and pixel tags
Apart from cookies, we also use other similar technologies such as website beacons and pixel tags on our websites. For example, emails we send to you may contain links to our website content, where when you click on the link, we will track the visit to help understand your product or service preferences so that we can actively improve customer service.
Website beacons are usually transparent images embedded in websites or emails. With the help of pixel tags in emails, we can find out whether the email was opened. If you do not want your activity to be tracked in this way, you can unsubscribe from our mailing list at any time.
How we store your information
The information and materials we collect about you will be stored on servers controlled, used and leased by us and/or our affiliated companies. We will strictly maintain the confidentiality and control of your information. This information and material may be transmitted in your country, region or place where we collect, store, access and display the information and material.
How we protect your personal information
Technical protection:
To ensure the security of your information, we strive to adopt a variety of reasonable physical, electronic and management security measures in accordance with industry standards.
This is done to protect so that your information will not be leaked, damaged, or lost, including but not limited to SSL, encrypted information storage, and data center access controls.
We will use encryption technology to increase the security of personal information, and will use trusted protection mechanisms to prevent personal information from being threatened. In addition we will also use access control mechanisms to try to ensure that only authorized personnel can access personal information.
Security system guarantee:
We have the highest data security management system in this industry, where our system collects data life cycle. This can improve the security of the entire system starting from organizational construction, system design, personnel management, product technology, and others.
Data retention period:
We will take reasonable and appropriate measures to avoid collecting irrelevant personal information. We will only retain your personal information for the period necessary to achieve the purposes stated in the company's fees policy, unless you agree to an extended retention period or are permitted by law.
Personnel security management:
We have also adopted strict management of employees or outsourced personnel who may come into contact with your information, including but not limited to taking control of different authorities according to different positions, signing confidentiality agreements with them, as well as monitoring operations and other actions. We will provide appropriate security measures to protect your information in accordance with existing technology and provide reasonable security assurance. We will do our best to prevent your information from being leaked, damaged or lost. We will organize security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information.
Tips for sensitive information and password protection :
Protection of sensitive personal information: Information that you voluntarily share or even share publicly when using our services may involve personal or even personally sensitive information of you or others. For example, when uploading personal information as your profile avatar or into comments, please take extra care when sharing relevant information when using our services. Please use a complex password to help us keep your account secure. We will do our best to best to ensure the security of the information you send to us. If our physical, technical or management protection facilities are damaged resulting in unauthorized access to information, public disclosure, or embezzlement and destruction of information, as well as damage to your legitimate rights and interests, then we will be responsible in accordance with applicable law.
Your account has security protection function, please save your account information and password properly. We ensure that your information will not be lost, misused or changed by backing up on other servers, as well as encrypting user passwords and other security measures. Despite the security measures mentioned above, please also understand that there is no "perfect security measure" on information networks.
Tips for disclosing information and dealing with password leaks:
Please note that the Internet is not a completely secure environment. When using certain services on our platform, you will not disclose your personal information, such as bank account information, contact information or home address, to partners, potential partners and parties on our behalf. Please protect your personal information properly and provide it to others only when necessary. If you find that your personal information has been leaked, especially if your account and password have been leaked, please contact our customer service immediately so that we can take appropriate further action.
Handling information security incidents:
When an unfortunate personal information security incident occurs, we will notify you of the basic situation and possible impact of the security incident in accordance with legal and regulatory requirements, and the steps we have taken or will take, and provide recommended solutions for you to take. itself, namely prevention and risk reduction, as well as other things. If this occurs, we will notify you via email, letter, telephone, push notification, etc. And if it is difficult to notify users of such information one by one, then we will adopt a reasonable and effective way to make announcements. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.
To provide you with security protection:
To enhance the security of your use of us, our affiliates and partners to provide services, protect your or other users' safety or public private property from breaches, and prevent phishing and fraudulent websites, network vulnerabilities, computer viruses, network attacks, network intrusions and risks other security, to more accurately identify violations of laws and regulations or agreement rules related to our platform, then we may use or integrate membership information, transactions, equipment and related information Web logs and information that our affiliates and partners obtain from you, these carried out for authorization or sharing in accordance with the law to comprehensively consider the risks of your accounts and transactions, carry out identity verification, security incident detection and prevention, and take necessary records, audits, analysis and deletions in accordance with applicable laws and measures.
Protection of minors , we attach great importance to the protection of personal information and the safety of minors' lives.
According to Law No. 22 of 2009 Article 77 Paragraph 1 of the "Traffic and Road Transport Regulations of the Republic of Indonesia", riding bicycles, tricycles, motorbikes and motorized wheelchairs for disabled people on the road must comply with the following regulations:
Drivers of electric bicycles and disabled wheelchairs must be at least 17 years old. The company's products are prohibited for use by persons under 17 years of age. If this situation causes personnel and economic losses, then this is your own responsibility.
How you manage personal information
We provide easy methods to enable you to access, correct and delete your account information or other personal information that you provide when using our services in accordance with the requirements of the "Network Security Law of the Republic of Indonesia". You can access and manage your personal information in the following ways:
Access to your personal information
Apart from those excluded by law and regulations, you have the right to access your personal information, in the following ways:
Account Information: If you wish to access or modify the personal information in your account, then you can do so through "Account Management" by logging into your account. For example, you can log in to the SWAP APP and go to "My Account" to access and modify your personal data and registration information.
Corrections or additions to your personal information
When you discover that the personal information we process about you is incorrect, you have the right to ask us to make corrections or additions. You can make corrections or additions by the methods listed in "(1) Access to your personal information".
Delete your personal information
You can delete some personal information in the ways listed in "(1) Access to your personal information". In the following situations, you can send us a request to delete personal information:
If our handling of personal information violates laws and regulations;
If we collect and use your personal information without your consent;
If our handling of personal information seriously violates an agreement with you;
If you no longer use our products or services, or you actively cancel your account;
If we no longer provide you with a product or service forever.
If we decide to respond to your account deletion request, we will also notify the subjects who obtained your personal information from us as much as possible, and request that such information be deleted in a timely manner, unless otherwise required by laws and regulations, or these subjects obtain authorization your independence.
When you delete information from our services, we may not immediately delete the appropriate information from the backup system, but will delete the information when the backup system is updated.
Changes in the scope of your legal permissions , every business function requires some basic personal information to be completed. In addition, for the collection and use of additional personal information, you can set in “My Account Management” or contact customer service on our platform to provide or withdraw your formal consent.
When you withdraw your consent, we will no longer process your personal information. However, your decision to withdraw consent will not affect processing of personal information previously carried out based on your authorization .
Regarding account cancellation personal information , if you wish to no longer use the service, then you can contact our platform customer service. After verifying the user's identity, customer service will release the user's mobile phone and mailbox data to authorize the cancellation.
[clear data before deleting account]
Once you knowingly delete your account, we will stop providing you with product or service information, and delete your personal information or anonymize it in accordance with applicable legal requirements.
Warning for you to pay attention to: before account deletion, if there are encountered some circumstances that cause the cancellation may not be resolved immediately, then you should deal with the following matters in time, such as:
As an electric motorbike user, the electric motorbike has not been returned to its owner intact :
The plate/frame number has not been released from the user account;
The continuous plan payment service has not been turned off;
H debt is not settled (including actual mileage exceeding the total mileage included in the package);
The package validity period has not expired ;
Automatic decisions from information system constraints
In some business functions, we can only make decisions based on non-manual, automated decision-making mechanisms including information systems, algorithms, and others. If this decision significantly affects your legal rights and interests, then you have the right to ask us to make an explanation, and we will also provide a complaint method without violating our platform's trade secrets, other users' rights, users' interests or social and public interests.
Respond to your request
To ensure security, you must provide a written request or prove your identity. We will ask you to verify your identity before processing your request. We will respond within 15 days. If you are not satisfied, you can also submit a complaint via customer service on our platform. For your reasonable requests, we will not charge a fee in principle, but for repeated requests that exceed reasonable limits, we will charge certain fees accordingly. We may reject unreasonably repetitive requests that require excessive technical means (for example, need to develop a new system or fundamentally change existing practices), and pose a risk to the legitimate rights and interests of others, or are simply unrealistic.
In the following situations, as required by law and regulations, we will not be able to respond to your request:
Related to national security and national defense security;
Relating to public safety, health and public interests;
Related to criminal investigations, prosecutions, trials and execution of decisions, and other matters.
There is sufficient evidence that the subject of personal information is subjectively harmful or abuses his or her rights;
Requests that would result in serious harm to the legal rights of you or other individuals and organizations;
Trade secrets are involved.
How your personal information is transferred globally , personal information that we collect and generate during our operations in the Republic of Indonesia is stored in Indonesia, except for the following situations:
Laws and regulations have clear provisions;
Obtain your authorization; In response to the above situations, we will ensure that your personal information is adequately protected in accordance with this privacy policy.
Revisions and updates to this privacy policy . Our platform reserves the right to change the privacy policy and notify you through our platform announcements or other appropriate means before the amendments take effect. In this case, if you continue to use our services, then you agree to be bound by the revised privacy policy of our platform. Without your consent, we will not limit your rights under this privacy policy. We will inform you of all changes and updates to the privacy policy on the special SWAP APP link. For major changes, we will also provide appropriate notifications (including we will notify you through our platform and even provide you with a pop-up prompt).
Major changes referenced in this policy include but are not limited to:
Our service model has undergone major changes. Such as the purpose of processing personal information, the type of personal information processed, and the use of personal information, and other matters.
We have experienced major changes in control in other aspects. Changes in ownership caused by mergers and acquisitions, etc.;
The primary object of personal information sharing, transfer or public disclosure has changed ;
Your rights to participate in the processing of personal information and the way you use it have changed significantly ;
When our department responsible for handling personal information security, contact information and complaint channels changed;
When the assessment report has an impact on the security of personal information that indicates a high risk.
We archive the old version of our platform user agreement and privacy policy in the "SWAP" APP for your reference.