1. THE INFORMATION WE COLLECT IN THE PLATFORM

Your personal information will be collected, recorded and used for the purpose described in this Policy. Personal Information as stated in this Policy refers to any and all information, data and/or documents that identify, contact, or locate the person or device associated with the information (“Personal Information”) that you provide to us and/or obtained, downloaded, retrieved or received from you or your electronic device, whether it is your and/or your End Customer’s Personal Information.

1. Information you provide to us and collected by us
   To use and/or utilize the Platform, you are required to provide us with certain Personal Information for the registration process which may include (i) company’s name or business name (if the Client is an individual entity), (ii) category or line of business, (iii) authorized User’s email and/or (iv) authorized User’s phone number.
   
   To use and/or utilize the Platform, you are also required to provide us with certain Personal Information of your End Customer which may include (i) name, (ii) mobile phone number, and (iii) social media username (if applicable).
2. Information collected by Client
   You may store or upload your and/or your End Customer’s Personal Information into the Platform. We have no direct connection with your End Customer’s Personal Information. You are responsible for providing notice and getting consent to and from your End Customer concerning the usage of their Personal Information and how their Personal Information is processed in or through the Platform.
3. Automatically collected information
   Our servers automatically collect limited information about your device's connection to the internet, including your IP address when you visit or use the Platform. We automatically receive and record information from you including but not limited to your IP address, your device or computer name, and your operating system. We may also collect log information from your device, including but not limited to your location, IP address, your device name, device serial number or unique identification number (e.g. IDFA on your iOS device, Android ID or ADID on your Android device), your device's operating system, browser type and version, CPU speed and connection speed, and so on.
   
   In order to improve the responsiveness of the Platform, we may use “cookies” or similar electronic tools to collect information to assign a random and unique number as a user identification (user ID) for each Client or User to understand our Client and User interests. By visiting or using the Platform, you consent to the use of cookies and similar technologies for the purposes we describe in this Policy. If you choose not to accept cookies, then you should stop using the Platform, or check your third party browsing and cookie settings. We use cookies and other technologies to analyze and optimize the Platform and for marketing purposes. Partners we work with may also set their own cookies to your search engine (browser), which is a process that we have no control over.
   
   Any information you provide will not be considered Personal Information if it is freely available and/or accessible in the public domain or is not considered Personal Information under the applicable laws and regulations. Furthermore, reviews, comments, messages, blogs published / uploaded / submitted / communicated by you in public sections of the Platform or application stores (such as the App Store or Play Store) become published content and are not considered Personal Information subject to this Policy.
4. Links to third party sites/ad servers
   This Platform may include links to other websites such as advertisements, blogs, sponsored content, vendor services, social networks, etc. Such websites are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can find out where you are by checking the URL in the location bar of your browser), the use of any information you provide is governed by the privacy policies of the operators running the sites you visit and we make no representations or warranties regarding how your information is stored or used on third party servers. These policies may differ from ours. If you are unable to find the privacy policy of one of these sites via the link on the website's homepage, you should contact the website directly for more information.
5. Information from other sources
   We may obtain information, including Personal Information, from third parties and sources other than the Platform, such as our partners, advertisers, and other parties who provide services to us, who collect your Personal Information and/or perform tasks on our behalf, or with whom we cooperate. If we combine or associate information from other sources with Personal Information that we collect through the Platform, we will treat the combined information as Personal Information in accordance with this Policy.
6. Demographic and Related Information
   We may reference demographic sources and other relevant information to provide you with targeted communications and promotions. We use Google Analytics, which among other things, is used to track your behaviour on the Platform.

2.  HOW WE USE THE INFORMATION WE COLLECT

We may use Personal Information obtained and collected from you for the purposes of (i) registration on the Platform, (ii) advertising or marketing for analytical purposes, (iii) providing services/features on the Platform, (iv) using information obtained from you to the purpose of research, analysis, product development, and testing in order to improve the security of our services on the Platform, also to develop new features and products, (v) monitor or investigate suspicious activities or activities that are indicated to contain elements of fraud or violations of the Terms of Use or applicable laws and regulations, and take necessary actions as a follow-up to the results of monitoring or investigating such activities, (vi) in certain circumstances, we may need to use or disclose your Personal Information for law enforcement purposes or to fulfill applicable laws and regulations requirements and/or obligations, including if a dispute occurs, or suspected criminal acts such as fraud or data theft, and (vii) in general, to optimize the performance of the Platform.

In an effort to improve our services, we may, from time to time, collect other information (other than as stated above) from you through the Platform by first informing you of the purpose for which the relevant information is collected and obtaining your consent for the collection of the information. You can rest assured that we do not share this information with any third parties except in accordance with the terms of this Policy. But if you choose not to submit/give information as requested, we may not be able to provide you with certain parts of the services on the Platform, we will make reasonable efforts to inform you in a timely manner. However, we will not be obliged and/or responsible for unavailability of certain parts of the service on the Platform because we do not receive the required information from you.

3.  TO WHOM WE DISCLOSE INFORMATION

You hereby understand and agree that the information (including Personal Information) collected may be shared with (i) our affiliates and group companies to the extent necessary for our internal business and/or administrative purposes and/or general company operations, and (ii) any third party service providers who work with us, to provide services on the Platform or to help us analyze how services are used. Third party service providers have access to information only to perform tasks on our behalf and they have an obligation not to disclose or use the information for any other purpose. We will take reasonable steps or actions to ensure that these third party service providers are obligated to protect your Personal Information and are also subject to confidentiality obligations and comply with applicable data protection laws.

In addition, you hereby understand and agree that we may also send your e-mail address and telephone number information to other third parties we work with for marketing, non-marketing or administrative purposes (such as informing you about major changes, for customer service purposes, providing information regarding updates to the Platform, billing, etc.). Further, you also agree to share information (including Personal Information) when requested or required by law or a court or governmental agency or authority to disclose, for purposes of identity verification, or for prevention, detection, investigation or for prosecution and punishment of violations. This disclosure is made in good faith and the belief that such disclosure is reasonably necessary to enforce the Terms of Use or to comply with applicable laws and regulations.

By using the Platform and providing Personal Information to us, you agree and consent to the disclosure, transfer, storage and processing of Personal Information by us in Indonesia and/or other countries from our affiliates, group companies, and third parties.

If we are involved in a merger, acquisition, bankruptcy, change of control, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership for the sole purpose of continuing the operation of the Platform, your Personal Information may be transferred or disclosed in connection with such business transactions to one or more third parties.

4.  YOUR RIGHTS AND CHOICES

1. Access, Correction, Deletion
   We respect your privacy rights and provide you with reasonable access to the Personal Information that you may have provided through your use of the Platform. If you wish to access or amend any other Personal Information we hold about you, or to request that we delete or transfer any information about you that we have obtained, downloaded, retrieved or received you may contact us as set forth in the “How to Contact Us” section.
   
   You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Platform. Please note that while any changes you make will be reflected in active user database instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
   
   You may decline to share certain Personal Information with us, in which case we may not be able to provide you some of the features and functionality of the Platform.
   
   At any time, you may object to the processing of your Personal Information, on legitimate grounds, except if otherwise permitted by applicable laws and regulations. If you believe your right to privacy is granted by applicable data protection laws has been infringed upon, please contact us as set forth in the “How to Contact Us” section.
   
   This provision does not apply to Personal Information that is part of your End Customer data. In this case, the management of your End Customer data is subject to your own privacy policy, and any request for access, correction or deletion should be made to your responsible for uploading and storage of such data into the Platform.
2. Navigation Information
   You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
3. Opting out from Commercial Communications
   If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.
   
   Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our services.

We have no direct connection with your End Customer or third party whose Personal Information may be processed on your behalf. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to you. If you want to remove your End Customer’s data, you should contact us as set forth in the “How to Contact Us” section and we will surely respond to your request in a timely manner. We will delete, amend or block access to any Personal Information that we are storing only if we receive a written request to do so from you, who is responsible for such Personal Information, unless we have a legal right to retain such Personal Information. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation.

5.  DATA SECURITY

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. Our security measures are reviewed and updated regularly to reflect technological developments. Regardless of where your Personal Information is transferred or stored, we take all steps reasonably necessary to ensure that Personal Information is stored securely. We maintain appropriate administrative, technical and physical safeguards to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. This includes, for example, firewalls, password protection and other access and authentication controls.

However, no method of transmission over the internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Platform, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Information has been compromised, please contact us as set forth in the “How to Contact Us” section.

If we learn of any security system breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable laws and regulations.

6.  DATA STORAGE

Your Personal Information will only be retained for as long as necessary to fulfill the purpose for which it was collected, or for as long as such retention is required or permitted by applicable laws and regulations. We will stop storing Personal Information, or remove the intent of relating such Personal Information to you as an individual, as soon as it is deemed that the purpose for which the Personal Information was collected is no longer required by storing Personal Information and retention is no longer necessary for business or legal purposes.

Please note that there is still a possibility that some of your Personal Information may be stored by other parties, including by government agencies in some way. In the event that we share your Personal Information with authorized government agencies and/or other institutions that may be appointed by government authorities, you agree and acknowledge that the storage of your Personal Information by the relevant institutions will follow the policies of each institution regarding data retention. You agree to indemnify, defend and hold harmless 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 not limited to legal costs and expenses on a full indemnity basis) resulting directly or indirectly from the unauthorized storage of your Personal Information.

7.  CHANGES AND UPDATES TO THIS POLICY

We may change our Policy from time to time to implement necessary changes in technology, applicable law or otherwise. In any case, we reserve the right to change (at any time) the terms of this Policy. Any changes we make will take effect immediately upon notification we give by posting the new Policy on the Platform. It is your responsibility to check this Policy periodically for changes. We may also make reasonable efforts to notify you by electronic mail (email). In any case, you are advised to periodically review this Policy on the Platform to ensure that you are aware of the latest version of this Policy.

If you do not accept the changes of this Policy, you shall notify us and this Policy will be terminated on the effective date of the modification and you should not access or use the Platform. Your continued use of the Donut Services, or any part or element thereof, after the effective date of the changes shall indicate your consent to the changes. We shall not be liable to you or to any third person for any changes, suspension or discontinuance of the Donut Services, or any part or element thereof.

8.  HOW TO CONTACT US

Please contact us with any questions or comments about this Policy, your Personal Information, our use and disclosure practices, or your consent choices by:

Email: chatsupport@lummo.com