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Shoda

PRIVACY POLICY

This Privacy Policy or Privacy Notice (“Privacy Notice”) is effective as of November 30, 2024.


The following Privacy Notice explains how We, Shoda and/or its affiliates (hereinafter referred to as “Shoda” or “We”) obtain, collect, store, control, use, process, analyze, correct, update, display, announce, transfer, disclose and protect Your Personal Data (“Processing Personal Data” or conducting “Processing Personal Data”). This Privacy Notice applies to all Users of Our mobile applications, websites (including www.shoda-apps.com and its derivative sites), features, services, and products (hereinafter referred to as “Apps”), unless otherwise regulated in a separate privacy notice.

This Privacy Notice is provided in a layered format so that you can click through to specific areas provided below. Please read this Privacy Notice in its entirety to ensure that you understand Our data protection practices. We want to make this easy to understand, so We have summarized the highlights in the Summary section.

Capitalized terms used in this Privacy Notice shall have the same meaning as such terms in the Terms and Conditions applicable between you and Shoda. The Privacy Notice shall also have the same meaning as the privacy policy as stated in the Terms and Conditions of the Application and products in Our Application.

 
ACKNOWLEDGEMENT AND CONSENT

By agreeing to the Privacy Notice, you acknowledge that you have read and understood this Privacy Notice and agree to all its terms. In particular, you agree and consent to Us Processing Your Personal Data in accordance with this Privacy Notice.

If you provide Us with Personal Data relating to another individual (such as Personal Data relating to your spouse, family member, friend or other party), then you represent and warrant that you have obtained the consent of that individual, and hereby consent on behalf of that individual, to Our Processing of their Personal Data. We may ask you for proof of such consent at any time.

You may withdraw your consent to any or all Processing of your Personal Data at any time by giving Us reasonable notice in writing using the contact details set out below. You may also withdraw your consent by using the “unsubscribe” option available in the messages We send, or using the options available on each communication medium We use to contact you.

You must understand and acknowledge that upon such withdrawal of consent, you may no longer be able to use the Application or services. Withdrawal of your consent may result in termination of the service, deletion of your account or termination of your contractual relationship with Us, with all rights and obligations arising therefrom remaining fully fulfilled.

Upon receipt of your withdrawal of consent, We will inform you of the possible consequences of such withdrawal so that you can decide whether you still wish to withdraw your consent.

SUMMARY

What data do we collect about you?

We collect Personal Data when you use our Application, including identity data, contact data, eligibility data, transaction data, financial data, payment data, log data and/or location data. We also collect device and technical data from you, and other data that you may provide or submit when you use our Application. If you choose not to provide such data, we may not be able to provide our services and Application to you normally.

How do we use data about you?

We use your data to set up and manage your account with us, communicate with you, and to provide you with various features, services and functions on our Application.


If you are a Seller or other third party, we use your data to verify that you are eligible to sell on our Application, to enable you to provide your Goods, digital products or financial products to Users, to set up and manage your account with us, communicate with you, and otherwise provide you with various services and functions available on our Application.


We also use your data to perform maintenance on our Application, and to tailor our products and services to your preferences. In addition, We use your data to market Our products and services to you, as well as the products and services of Our affiliated companies, partners, or agents (with your consent if required by Applicable Laws and Regulations).

Who do we share your data with?

We share your data with our third party partners to facilitate the performance of services for or by you, with our third party partners, to the extent necessary for them to provide their services, including but not limited to, payment processing, delivery of goods, provision of products, insurance claims and verification.

We use these third party services solely to process and/or store your data for the purposes described in this Privacy Notice. We also share your data with our affiliates for the purposes described in this Privacy Notice and with government agencies and other government authorities as required by Applicable Laws and Regulations.

We may also provide access by displaying your Personal Data to other Users to facilitate communication and/or the implementation of service fulfillment in our Application.

Where do we process your data?

We process your data in several locations, both in Indonesia and outside Indonesia. We may also transfer your data to our affiliates and third party partners outside Indonesia for the purposes set out in this Privacy Notice.

How long do we process your data?

We process your data as long as you give your consent and it is necessary to fulfill the purpose of its acquisition and collection, or as required by Applicable Laws.

How can I exercise my rights over my data?

You may have various rights in relation to your Personal Data under Applicable Laws.

If you wish to apply for the exercise of your rights, you may submit a data subject rights application to Shoda, including a request for deletion of User data through Our Application.

How will we notify you of changes?

We will change this Privacy Notice from time to time and notify you of the updated version through Our Application or your email registered with Us.

Please check back periodically for any updates or changes to this Privacy Notice. Further explanation of the above can be read in the section below.

Contact Us

If the User has any questions, comments, complaints, or claims regarding this Privacy Notice or the User wishes to obtain access and/or make corrections to his/her Personal Data, please contact Shoda customer service.

PERSONAL DATA WE COLLECT

Types of Personal Data We Collect About You

“Personal Data” means data that identifies or can be used to identify, contact, or locate the person or device to whom such data relates. Personal Data includes, but is not limited to, name, address, date of birth, occupation, telephone number, email address, bank account and credit card details, gender, identification (including passport or national identity document) or other government-issued identification, vehicle data, photograph, citizenship, telephone numbers of Users and non-Users in your mobile phone contact list, health data, financial data, biometric data (including but not limited to fingerprint recognition and facial recognition), and other data that is considered Personal Data in accordance with applicable laws and regulations. For the avoidance of doubt, applicable laws and regulations means all applicable statutes, bylaws, regulations, regulatory policies, ordinances, protocols, industry codes, road traffic codes, regulatory permits or requirements of any court, tribunal or government, enactment, rule, judicial, administrative or regulatory authority or body, in force from time to time during the term of this Privacy Notice (“Applicable Laws and Regulations”). In addition, if other data, including personal profiles and/or unique identifiers, is associated or combined with Personal Data, then such data also constitutes Personal Data.

The type of Personal Data We collect depends on the circumstances of collection and the nature of the services requested or transactions undertaken.

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

  1. Identity Data including name, username, password, national identity card, taxpayer identification number, user identity or other identifier, position, date of birth, gender, place of birth, occupation, nationality, photograph and/or biometric data.
  2. Contact Data including billing address(es), delivery address(es) and labels, email address(es), telephone number and contact list.
  3. Eligibility Data including, in relation to Sellers, such as licenses, approvals and insurance policy details.
  4. Transaction Data including purchases or orders you make, your interests, preferences, feedback and survey responses, in relation to Users, the type of service sought, details regarding pickup and/or delivery, and the type of service acceptable at that time.
  5. Financial Data includes bank account and payment card details such as the type of payment card or account used, the name of the issuer of the payment card or account, the name of the holder of the payment card or account, the identification number of the payment card or account, the verification code of the payment card or account, and the expiration date of the payment card or account, as applicable, virtual account data, financial history (including but not limited to payment card or account transaction history, payment card or account details, CVV code and mapping and/or status and condition of the payment card or account), and credit scoring data.
  6. Payment Data includes details of payments or transfers made by Users on Our Application, including but not limited to data relating to usage, payments, recipient details (including their account details), payment method used, amount paid, billing details, and invoice details.
  7. Technical Data includes details about your use of Our Application such as identification generated by the Application (user id) internet protocol (IP) address, data as previous or subsequent web pages viewed, duration of each visit/session, internet device identity (ID) or media access control address, advertising ID and other device information including information regarding the manufacturer, model, and operating system of the device you use to access the Application and crash logs.
  8. Device Data includes device data, including the type of device you use to access the Application, including hardware model, operating system and version, software, IMEI number, file name and version, language selection, unique device identifier, advertising identifier, serial number, device movement information, and/or cellular network information.
  9. Log Data includes records on servers that receive data such as device IP address, date and time of access, application features or pages viewed, application work processes and other system activities, browser type, and/or third-party sites or services that the User uses before interacting with the Application.
  10. Location Data includes your real-time geographic location data, location coordinates in the form of longitude latitude, and Wi-Fi location.

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

If You Provide Incomplete Personal Data

When We need to collect Personal Data by law, or under the terms of an agreement We have with You, and You choose not to provide such Personal Data or provide incomplete Personal Data to Us when requested, We may not be able to provide the services and perform the agreements We have or are in the process of entering into with You.

How We Collect Your Personal Data

The Personal Data We collect may be provided by You directly or by a third party (for example: when You register or use the Application, when You contact Our customer service, or otherwise when You provide Personal Data to Us). We may collect data in various forms and for various purposes (including purposes permitted under Applicable Laws and Regulations).

  1. Data We collect from You or Your mobile device directly

You may provide Us with Identity, Contact, Eligibility, Profile, Financial and Payment Data, including in circumstances where it is requested by Us or in circumstances required by Applicable Laws and Regulations, when interacting with Us directly or corresponding with Us via letter, email or otherwise.

This includes Personal Data that You provide when You:

  1. register and create an account using the Application;
  2. use the Application, including if You register as a Seller or use the services as a User;
  3. make payments using available methods including but not limited to payment using credit cards, bank transfers, direct payment facilities to Shoda offices in each destination country.
  4. using the email feature (including but not limited to product discussions, communicating with Shoda, communicating with customer service); and
  5. providing feedback or contacting Us.
  1. Data collected whenever you use the Application

You may provide Us with Technical and Location Data whenever you use and/or visit the Application. Whenever you access the Application through your mobile device, We will track and collect your geographic location data in real-time. In some situations, you will be asked to enable the Global Positioning System (GPS) on your mobile device so that We can provide you with a better experience in using the Application. You can always choose to temporarily disable geographic location tracking data on your mobile device. However, it may affect the functionality available on the Application.

In addition, whenever you use and/or visit the Application, certain data may also be collected automatically using cookies. Cookies are small application files that are stored on your computer or mobile device. We use cookies to track User activity to improve the User interface and experience. Most mobile devices and internet browsers support the use of cookies; however, you can adjust the settings on your mobile device or internet browser to reject certain types of cookies or certain specific cookies. Your mobile device and/or browser also allows you to delete any cookies that have been previously stored at any time. However, this may affect the functionality available on the Application. Shoda may also use features provided by third parties in order to improve Shoda’s services and content, including assessing, customizing, and presenting offers to each User based on their interests or browsing history. If the User does not want offers to be displayed based on such customization, the User can set this via the browser.

  1. Data collected from third parties

We may also collect your Personal Data from third parties (including agents, vendors, suppliers, contractors, partners, government agencies and others who provide services to Us, collect Personal Data and/or perform tasks on Our behalf, or with whom We collaborate). In such cases, We will only collect your Personal Data for or in connection with the purposes for which such third parties are involved or the purposes for which We collaborate with such third parties (as the case may be). In particular, when you register a payment card or account through the Application and/or access, add and/or link your payment card or account to the Application (as applicable in your country), We may collect certain financial data and financial records about you (including but not limited to transaction records, payment card or account details and placement, and/or the status and country of your payment card or account) from the issuer of such payment credentials or from other third parties.

  1. Data about third parties that you provide to Us 

You may provide Us with Personal Data relating to other third party individuals (including Personal Data relating to your spouse, family members, friends or other individuals). In such circumstances, you will of course need the consent of those other third party individuals — see “Acknowledgement and Consent,” above, for more information.

USE OF PERSONAL DATA

How We Use Your Personal Data

We may use the Personal Data collected for the following purposes or for other purposes permitted by Applicable Laws and Regulations (“Purpose”):

  1. If you are a User, We may use your Personal Data:
    1. To identify and register you as a User and to create, verify, deactivate, or manage your account on Our Application.
    2. To facilitate or enable any verification that We deem necessary before the Seller provides its services or before We register you as a User, including conducting KYC (Know Your Customer) and/or credit scoring (if required);
    3. To enable Shoda to provide services, whether services that are already available, services that you request, or services that will be available in the future;
    4. To process and facilitate orders and payment transactions that you make, including as applicable, transactions made through payment cards, accounts available on the Application, and/or direct payments to Shoda offices.
    5. To notify you of transactions or activities occurring within the Application or other systems connected to Our Application;
    6. To communicate with you and send you data in connection with your use of the Application;
    7. To notify you of any updates to the Application or changes to the services provided;
    8. To process, resolve and respond to complaints, problems, questions and suggestions received from you;
    9. To maintain, develop, test, improve and personalize the Application to meet your needs and preferences as a User, including enabling features to personalize User accounts, such as Shopping Cart, Wishlist and Favorite Stores;
    10. To monitor and analyze user activity, behavior and demographic data including habits and usage of various services available on the Application;
    11. To process and manage your reward points;
    12. To offer or provide services from Our affiliates or partners; and
    13. To send you direct or targeted marketing communications, advertisements, vouchers, surveys and data, and data about special offers or promotions and when such events, promotions, features or launches occur.
       
  2. If you are a Seller, We may use your Personal Data:
    1. To identify and register you as a Seller and to create, manage or verify your account on Our Application;
    2. To facilitate or enable any verification that We consider necessary before We can register you as a Seller, including for KYC (Know Your Customer) and/or credit scoring (if required);
    3. To enable you to provide services to Users;
    4. To process, facilitate and settle payments to you in relation to the services you have provided;
    5. To send you information relating to the provision of your services, including to deliver User orders to you and to facilitate your acceptance of such orders;
    6. To provide you with notifications and updates on the Application or changes in the manner in which services are provided;
    7. To provide you with reports relating to the services you have provided;
    8. To process, resolve and respond to suggestions, complaints or issues from Users regarding the services you have provided;
    9. To maintain, develop, test, improve and personalize the Application to meet your needs and preferences as a Seller;
    10. To monitor and analyze User activity, behavior, and demographic data including Seller habits and responsiveness to various services available on the Application;
    11. To process and manage your reward points;
    12. To offer or provide services from Our affiliates or partners;
    13. To send you marketing communications, advertisements, promos, surveys, and special offers or promotions directly or targeted and when such events, promotions, features, or launches occur.
  3. Whether you are a User or a Seller or a party providing Personal Data to Us, We may also use your Personal Data more generally for the following purposes (although in certain circumstances We will always act reasonably and not use your Personal Data more than is necessary for those purposes):
    1. To perform related business processes and functions;
    2. To monitor the use of the Application and manage, support and improve the efficiency of the performance, growth, user experience and functionality of the Application;
    3. To provide assistance in connection with and to resolve technical difficulties or operational issues with the Application or services;
    4. To generate statistical data and analytical data for the purposes of testing, research, analysis, product development, commercial partnerships and collaborations;
    5. To prevent, detect and investigate any suspicious transactions or prohibited, illegal, unauthorized or fraudulent activities;
    6. To facilitate business asset transactions (which may be mergers, acquisitions or asset sales) involving Us and/or Our affiliates;
    7. To enable Us to comply with all obligations under Applicable Laws and Regulations, including but not limited to responding to requests, inquiries or decisions in accordance with regulations, complying with filing, reporting and licensing requirements required by law or Applicable Laws and Regulations and conducting audits, due diligence and investigations; and
    8. For other purposes that We notify you and, if required by Applicable Laws and Regulations, We obtain your consent.

Disclosure of Your Personal Data

We may disclose, provide access to or share Your Personal Data with Our affiliates and other parties for the following purposes and for other purposes permitted by Applicable Laws and Regulations:

  1. if You are a User, to enable Sellers or partners to provide services or process orders, including to contact You;
  2. if You are a Seller or partner, to enable Users to request or receive services from You, including to contact You and to organize promotions, contests, or special services available on the Site, such as Shoda’s Trade-In or Direct Sale programs;
  3. to respond to regulatory inquiries, questions, requests, investigations, decisions, reporting, to comply with filing requirements and provisions, as specified in Applicable Laws and Regulations;
  4. if instructed, requested, required or permitted by an authorized government institution, for the purposes as stated in a letter, policy, government regulation or Applicable Laws and Regulations;
  5. if there is a legal process in any form between you and us, or between you and another party, in connection with, or related to the services, for the purposes of such legal process;
  6. in connection with any verification process we or third parties require before the Seller provides services to you or we register you as a User, including the KYC (Know Your Customer) process and/or credit scoring;
  7. when our services are available on any third party platform, (i) to help us obtain your Personal Data and/or (ii) register you or allow you to use our services on such third party platform;
  8. in an emergency related to your health or safety (whether you are a User or a Seller) for the purposes of handling such emergency;
  9. in situations related to your health or public interest (whether you are a Buyer or a Seller), we may share your Personal Data with authorized government institutions and/or other institutions that may be appointed by the authorized government or have cooperation with us, for the purposes of contact tracing, supporting government initiatives, policies or programs, public health and other purposes as reasonably required;
  10. in connection with, a merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of Our business by or to another company, for the purposes of such transaction (even if the transaction is not subsequently consummated);
  11. in connection with the insurance claims process, We will share Your Personal Data for the purposes of processing insurance claims with insurance brokerage firms and insurance companies that cooperate or collaborate with Us;
  12. to third parties (including agents, vendors, suppliers, contractors, partners and others who provide services to Us or You, perform tasks on Our behalf, or with parties who enter into commercial cooperation with Us), for or in connection with the purposes for which such third parties are involved, to carry out disclosures to relevant third parties that are technically necessary to process Your transaction or for the purposes of Our cooperation with such third parties (as the case may be), which may include allowing such third parties to introduce or offer products or services to You, authenticate You or connect You with an account or carry out other activities including marketing, research, analysis and product development; and
  13. with Our affiliates or other third parties who assist Us in providing the Application, to operate Our business (including, when You subscribe to a mailing list for direct marketing purposes) or for the purposes of processing data on Our behalf.

When there is Personal Data that does not need to be associated with You, We will make reasonable efforts to de-associate such Personal Data with You as an individual before disclosing or sharing such data.

We will not sell or rent Your Personal Data.

Other than as set out in this Privacy Notice, We may disclose and share Your Personal Data by notifying You or asking for Your consent for such disclosure or sharing.

PROTECTING YOUR PERSONAL DATA

Data Security

The confidentiality of your Personal Data is of utmost importance to Us. We will make every effort to protect and secure your Personal Data from unauthorized access, collection, use or disclosure and from unlawful processing, accidental loss, destruction and damage or similar risks. However, because data transmission via the internet is not completely secure, We cannot fully guarantee that such Personal Data will not be intercepted, accessed, disclosed, altered or destroyed by unauthorized third parties, due to factors beyond Our control. You are responsible for maintaining the confidentiality of your account details and must not share your account details, including your password and One Time Password (OTP) with anyone, and you must also always maintain and be responsible for the security of the device you use.

Data Storage

Your Personal Data will only be stored for as long as is necessary to fulfill the purposes for which it was collected, for the retention period or as long as such storage is required or permitted by Applicable Laws and Regulations. We will stop storing Personal Data, or remove the purpose of associating such Personal Data with you as an individual, as soon as it is deemed that the purpose for which such Personal Data was collected is no longer met by storing the Personal Data, there is a request from you to delete your account, and storage is no longer necessary for business or legal purposes.

Shoda will delete and/or anonymize User Personal Data under Shoda’s control if (i) the User Personal Data is no longer needed to fulfill the purpose for which it was collected; (ii) the retention period has expired and (iii) storage is no longer necessary for compliance purposes under applicable laws and regulations.

Please note that it is still possible that some of your Personal Data is stored or controlled by other parties including government institutions in certain ways. In the event that We share Your Personal Data with authorized government institutions and/or other institutions that may be appointed by the authorized government or have cooperation with Us, You agree and acknowledge that the storage of Your Personal Data by the relevant institutions will follow the data storage policies of each institution.

Data submitted through communication between Buyers and Sellers conducted other than through the use of the Application (such as through telephone calls, SMS, mobile messages or other means of communication and collection of your Personal Data by Our agents) may also be stored in several ways. We do not permit the Processing of Personal Data between Buyers and Sellers that occurs outside of Our Application. Therefore, Buyers and Sellers are fully responsible for the Processing of such Personal Data.

To the extent permitted by Applicable Laws and Regulations, You release Us from and against any and all claims, losses, liabilities, costs, damages, and expenses (including but not limited to legal fees and full compensation expenses) resulting directly or indirectly from any activity conducted outside of our Application.

YOUR RIGHTS AS A USER

Your Legal Rights

You may have certain rights under Applicable Laws to request from Us access to, correction of and/or deletion of Your Personal Data in Our possession and control.

We may refuse your request for access to, correction of and/or deletion of, some or all of Your Personal Data in Our possession or control if permitted or required under Applicable Laws. This includes circumstances where such Personal Data may contain references to other persons or where the request for access or request to correct or delete is for reasons that We deem irrelevant, frivolous, frivolous, or indicative of a breach of the terms and conditions or a breach of law.

In accordance with Applicable Laws, We reserve the right to charge an administrative fee for each request for access and/or correction.


ADDITIONAL NOTES

Websites and Other Services

The Application and Marketing Materials (as defined below) may contain links to websites operated by third parties. Any Processing of Personal Data on such websites is solely controlled by the third party and is the responsibility of the third party. If you agree to access websites operated by such third parties, then you are subject to the terms and conditions and privacy notices of such third party websites. Therefore, We recommend that you read the terms and conditions and privacy notices of such third party websites to find out how they collect and use your Personal Data.

When you use Our Application and enable fingerprint and/or facial recognition features on your mobile device for authentication purposes, please note that We do not store such biometric data. Unless otherwise notified to you, such data is stored on your mobile device and may be stored by third parties, such as your mobile device manufacturer. You agree and acknowledge that you are solely responsible for any unauthorized access to or loss of any biometric data stored on your mobile device.

Advertisements contained in Our Application or Marketing Materials serve as links to advertisers’ websites and as such any data they collect based on your clicking on such links will be collected and used by the relevant advertiser in accordance with that advertiser’s privacy policy.

Marketing and Promotional Materials

We and our partners (including vendors, suppliers, merchants and/or other third parties connected with us for commercial and/or non-commercial purposes) may send you direct marketing, advertising and promotional communications via push-notification applications, messages via the Application, post, chat platforms, social media and email (“Marketing Materials”) if you have agreed to subscribe to our mailing list, and/or agreed to receive marketing and promotional materials from us. You may opt out of receiving such marketing communications at any time by clicking the “unsubscribe” option in the relevant message, other methods available on the promotional media or contacting us using the contact details listed below.

Please note that if you opt out of receiving Marketing Materials, we may still send you non-promotional messages, such as receipts or data about your account.

Updates to the Privacy Notice

We may review and amend this Privacy Notice at our sole discretion from time to time, to ensure that it is consistent with our future developments and/or changes in applicable legal or regulatory requirements. If We decide to change this Privacy Notice, We will notify You of such changes through Our official channels. You agree that You are responsible for checking this Privacy Notice periodically for the latest data on Our data processing and data protection practices, and that Your continued use of Our Application or website, communication with Us, or access and use of the services after any changes to this Privacy Notice will be deemed as Your acceptance of this Privacy Notice and any changes.

CONTACT US

In the event that Users have questions, comments, complaints, or claims regarding this Privacy Notice or Users wish to obtain access, request deletion, make corrections and/or other rights to their Personal Data, please contact Shoda customer service.