Privacy Policy

OUR SERVICES

We take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of our Services is at all times subject to our T&C, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the T&C.

Effective From: 01/10/22

I. Personal Data

Personal data refers to all information, data and/or description in any form that can identify you, which from time to time you convey to us or that you include or convey in, on, and/or through when using our Services regarding information related to you personally ("Personal Data"). Personal Data includes but not limited to your full name, government-issued identification card number, address, date of birth, nationality, gender, mobile phone number (including but not limited to: IP address), location information, your device data, IMEI number, name of the application attached to your device), bank and credit card details, email address, your picture, biometric data, marital status, personal health information, insurance information, financial information, pet information and other data classified as personal data.

Please note that Personal Data does not include any personal information that is already available in the public domain.

II. Accuracy of Personal Data

1. We need your Personal Data, one of which is to be able to process transactions and facilitate our Services. Therefore, the Personal Data that you provide to us must be as accurate as possible and not misleading. You must update and notify us of any changes to your Personal Data. You hereby indemnify us from any demands, lawsuits, damages, and/or claims in connection with the failure of transaction processing or provision of our Services and the use of our Services caused by the inaccuracy of the Personal Data you provide to us.

2. If you are under the minimum age requirement or are included in the category of children in accordance with the provisions of the applicable laws and regulations, or are not married or under guardianship, then you need the consent of your parents, guardians or legal guardians to provide Personal Data to us. If your Personal Data is provided to us, you hereby represent and warrant that your parent, legal guardian or benefactor has consented to the processing of your Personal Data and individually accepts and agrees to be bound by this Privacy Policy and is fully responsible for your actions that are taken while using our Services.

3. In certain circumstances, you may provide Personal Data relating to other individuals (such as your spouse and/or family members). In such circumstances, 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 Data by us.

III. Personal Data Which We Collect

Personal Data collected when you use our Services, includes:

1. Personal Data collected from you as user of our services is as follows:

Personal Data submitted by you voluntarily and independently, including but not limited to Personal Data submitted when you:

Create or update your account, including but not limited to name, National Identity Number (NIK), date of birth, email, mobile number, address, photo, pet and/or other information;
Upload your Personal Data in connection with the provision of Services, including but not limited to your and/or your pet’s ID photo, gender, known health conditions, medications, allergies, vaccinations, medical history, health targets, health journal entries, prescriptions, reports, medical files, and/or other personal data, uploaded by you as a user from time to time when using our Services. This includes information about family members, friends, beneficiaries, beneficial owners, attorneys, persons under the trust, trustees, guarantors, other insurance providers, and/or other individuals provided by you;
Contact us, including but not limited to through our communication and support channels;
Submit any form, including, but not limited to, application forms or other forms relating to any of our Services, whether online or by way of a physical form;
Complete a survey sent by us or on our behalf;
Interact with us, such as via letters, face-to-face meetings, social media platforms and emails;
Participate in contests or events organised by us;
Fill in payment data when you carry out payment activities for our Services, including but not limited to credit card data (if applicable), and/or electronic wallet (e-wallet);
Use features that require access to your device; and/or;
Other data submitted through third party services in connection with the use of our Services.

Personal Data recorded when you use our Services, including but not limited to:

Real or estimated location data, including but not limited to IP address, Wi-Fi location, geo-location, GPS coordinates, and other information provided by your device. You may activate or deactivate location recognition service within your device when you use our Services;
Data in the form of your activities, including but not limited to registration activities, logins, use of our Services, payments (where we can store details of the online payment methods you use for our Services and transaction history), and others;
Data related to, if applicable, teleconsultation services (which includes chat, video and audio call features, including microphone permissions), when you consult with our qualified medical personnel via our Services. Our teleconsultation feature allows you to upload and/or download pictures, have real-time audio and/or video calls over the Internet with our qualified medical personnel relating to your pet’s medical conditions. Note: Audio and video permissions are only applicable when you are in a live teleconsultation chatroom and NOT when our Services is running in the background in your device. By using our Services, you are deemed to acknowledge and consent that any chat history services in text format may be collected, stored, utilized and/or disclosed by us in accordance with this Privacy Policy.
Services usage or configuration data, including your interactions in using our Services, saved options, and selected settings. The data is obtained using, including but not limited to cookies, pixel tags, and similar technologies that create and maintain unique identifiers;
Device data, including the type of device used to access our Services, including but not limited to hardware model, operating system and version, software, file name and version, language selection, unique device identifier, advertising identifier, serial number, device movement information, and/or cellular network information, as well as other additional data required by reference to a browser or application access request on your device;
Data records (logs), including records on servers that receive Personal Data such as device IP addresses, access dates and times, application features or pages viewed, application work processes and other system activities, browser type, and/or third-party sites or services which you used before using our Services; and
Data obtained from camera access activities on your device, the approval to of which is deemed to have been obtained when you use our Services for the first time and that access is only for certain features or services that must use the camera in order for using our Services to its full potential.

2. Operational data: To improve the experience of using our Services, we may use cookies, server logs and other similar mechanisms to enable certain functions, improve the Services, monitor the use of the Services, and for marketing purposes within and outside our Services. This mechanism is used to store user preferences, maintain session settings, assist with automatic authentication for frequently used Services if required by your setup, and enable other similar functional requirements. You can use your browser settings to disable cookies while using our Services. However, this may result in you being unable to access all or part of our Services, or to use all or part of the functionality of our Services. Our third-party partners may also automatically receive and store non-personal information or anonymous data about Your online activities over time.

3. Personal Data collected from other sources, including but not limited to:

Partners assisting us in the development and provision of our Services to you, including but not limited to payment service provider partners, delivery service provider partners, telecommunication company partners and/or other partners;
Third parties used by you as user to create or access an account, including but not limited to social media services, or sites or applications that we use;
Marketing service providers; and/or
Generally available sources. We may combine and/or process Personal Data obtained from these sources with other Personal Data belonging to us.

In the event that there is additional Personal Data that we collect from you, we will ask for additional consent from you while taking into account the protection of your Personal Data.

IV. The Use of Personal Data Which We Collect

1. We may use Personal Data collected for the following purposes or for other purposes permitted by applicable laws and regulations:

a. If you are a user, we may use your Personal Data:

to identify and register you as a user and to administer, verify, deactivate or manage your account to use our Services.
to facilitate or enable any verification that, in our consideration, is necessary before we provide the Services to you or before we register you as a user, including implementing the Know Your Customer (“KYC”) process;
to provide the Services that you request;
to process and facilitate your payment;
to inform you for any transaction or activities occurring when using our Services or other system connected to our Services;
to provide the creation of prescriptions and/or medicines according to your request in connection with our Services;
to communicate with you and send you information related with the use of our Services;
to diagnose and solve problems related to difficulties in accessing the Services (troubleshoot);
to notify you of updates and/or changes to our Services;
to maintain, develop, test, improve and personalize the Services to meet your needs and preferences as a user;
to monitor and analyze your activity, behavior and demographic data as a user including your habits and use of our various available Services;
to process and respond to questions, comments and feedback received from you;
to offer or provide services from our affiliates or partners;
to send you direct, targeted or personalized marketing communications, advertisement, vouchers, surveys, and information on special offers or promotions;
to provide information/send emails and/or SMS containing promotions periodically to you when there is an offer and/or promotion of new products, special offers, or other information that we deem is required by you; and/or
for any other purposes that we notify you of when we collect Personal Data.

b. We can also use your personal data more generally for the following purposes (although in certain cases we will act fairly and not use your Personal Data more than what is needed for the purpose):

to perform related business processes and functions;
to monitor the use of our Services and manage, support and improve the efficiency of the performance, development, user experience and functions of our Services;
to provide assistance in connection with and to resolve technical difficulties or operational problems with our Services;
to produce statistical information and analytical data for the purposes of testing, research, analysis, product development, commercial partnerships and collaborations; to prevent, detect and investigate any prohibited, illegal, unauthorized or fraudulent activities;
to facilitate business asset transactions (which can be in the form of mergers, acquisitions, or asset sales) involving us and/or our affiliates; and/or
to enable us to comply with all obligations under applicable laws and regulations, including but not limited to responding to requests, investigations, or regulatory directives, complying with filing, reporting, and licensing requirements required by applicable regulations) and conducting audit checks, due diligence and investigation.

2. You are allowed to share your Personal Data with other parties at your own risk. We are not responsible for the compliance of other parties, who will see and use any information disclosed by you, to the Privacy Policy.

3. We may also use Personal Data without consent, relying on legitimate interests or other exceptions provided by applicable data privacy laws, for purposes such as i) complying with applicable laws and regulations; ii) investigate potential fraud or illegal acts; or iii) protect our brand, our reputation or our ownerships. We may also use your Personal Data when we are required, advised, recommended, expected or asked to do so by our legal counsel or local or foreign legal counsel, regulatory, governmental or other authorities.

V. Sharing of Personal Data Which We Collect

We may disclose, provide access to or share your Personal Data with affiliates and other parties for the following purposes and for other purposes permitted by applicable laws and regulations:

if you are a user, to enable us to the Services;
if required or authorized by applicable laws and regulations (including but not limited to responding to inquiries regarding regulations, investigations or guidelines, or complying with statutory filing and reporting requirements or conditions), for the purposes specified in applicable laws and regulations;
if instructed, requested, required or permitted by the competent government, for the purposes as stated in the applicable government policy, regulation or legislation, including but not limited to where disclosure is required for medical review;
for the purposes of our and our affiliates’ internal investigations of criminal acts or violations of regulations or policies;
if there is a legal process of any kind between you and us, or between you and other party, in connection with, or related to the Services, for the purposes of the legal process;
in connection with all verification processes that we and/or third parties require before we provide Services to you or we register you as a user, including but not limited to the KYC process;
in an emergency regarding your or you pet’s safety for the purposes of dealing with such an emergency. This includes protecting our safety and that of our affiliated companies, your safety or the safety of others or for the legitimate interests of any party in the context of national security, law enforcement, litigation, criminal investigations or to prevent outbreaks, and/or state of emergencies as determined by the Government;
in situations related to your or your pet’s health or public interest, we may share your Personal Data with the competent government and/or other institutions that may be appointed by the competent government or have cooperation with us, for contact tracking purposes, support initiatives, policies or programs of government, public health and other purposes as reasonably necessary;
in connection with, merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or part of our business by or to another company, for the purposes of such transaction (even if the transaction is discontinued);
to third parties (including agents, vendors, suppliers, contractors, partners, and other parties who provide services to us or you, perform tasks on our behalf, or parties with whom we enter into commercial cooperation with), for or in connection with the purposes for which the third party is involved, to carry out disclosures to the relevant third party that are technically necessary to process your transaction related to any Services or the purpose of our cooperation with the third party (depending on the circumstances), which may include allowing the third party to introduce or offer products or services to you, authenticate you or connect you with our Services and/or perform other activities including selling, marketing, research, analysis and product development. In connection with this disclosure, we will make best efforts to protect your Personal Data, such as but not limited to being performed anonymously (by eliminating your personal identification) and carried out after signing a confidentiality agreement;
in the event that we share Personal Data with affiliates, we will do so with the intention that they assist us in providing Services within the Platform, to operate our business or for the purpose of processing Personal Data on our behalf. For example, our affiliate in another country may process and/or store your Personal Data on behalf of our group company in your country. All of our affiliates are committed to processing Personal Data they receive from us in accordance with this Privacy Policy and applicable laws and regulations; and/or
to carry out the activities as described in section IV (Use of Personal Data).

2. You are deemed to have agreed to allow certain third parties to use your Personal Data to provide you with information about the goods and services you may need. Such third parties include but are not limited to:

Service providers by third parties (including but not limited to: x-ray services or laboratory testing services) upon our referral;
Our business partners, such as pharmacy partners, billing services, or those who provide administrative services for us. We have underlying agreements with each of our business partners and service providers are required to protect the confidentiality and security of the information passed on to them.
Research and marketing companies related to promotions performed by us.
Service providers related to information technology (IT) such as infrastructure services, cloud computing, software, analysis development "Big Data" and "Machine Learning", including services to perform "Cleansing Data", "Data Insight", "Credit Scoring" and others.
Payment transaction processing service provider companies which include payment gateway providers, fund transfers, electronic wallets, and other payment system service providers related to transactions made in relation to our Services.

3. Where Personal Data does not need to be associated with you, we will make reasonable efforts to remove the Personal Data from being associated with you as an individual prior to disclosing or sharing such information.

4. In addition to as set out in this Privacy Policy, we may disclose and share your Personal Data if we notify you and we have obtained your consent for such disclosure or sharing.

VI. Cookies

1. Cookies mean small files that will automatically take place on our device which performs the function of storing your preferences and configurations while visiting a site. Cookies are not intended to be used when accessing other data that you have on your computer device, other than what you have agreed to submit.

2. Although your computer device will automatically accept cookies, you may choose to make modifications through your browser setting, namely by choosing to reject cookies (this option may hinder the optimal availability of our Services).

3. We are using Google Analytics. Data obtained by us from such features, such as age, gender, your pet, your interest and other identifiable information of you and/or your pet, will be used by us for the development of features, facilities and/or contents available on our Services. If you do not wish for Google Analytics to track your Personal Data, you may use Add-On Google Analytics Opt-Out within your browser.

4. We may use features provided by third parties for the purpose of improving our Services and contents, including the assessment, adjustment and serving of advertisements to you based on your interest or visit history of using our Services. If you do not wish for any advertisement to be displayed based on such adjustment, you may set it via your browser

VII. Storage of Personal Data

1. Your Personal Data that we collect may be stored, transferred or processed outside of Indonesia by parties working for us in other countries, or by third party service providers, vendors, suppliers, partners, contractors or our affiliates. we will reasonably endeavor to ensure that these third-party service providers provide an equivalent level of protection with our commitments under this Privacy Policy.

2. We will delete and/or anonymize your Personal Data which is under our control if (i) your Personal Data is no longer necessary to fulfil the purpose for which it was collected; and (ii) the retention is no longer required for the purpose of compliance with applicable laws and regulations.

3. Please note that there is still the possibility that some of your Personal Data might be retained by other parties, including by the government institutions in some manner. In the event we share your Personal Data with authorized government bodies and/or other institutions that may be appointed by the competent government or have cooperation with us, you agree and acknowledge that the storage of your Personal Data by these relevant authorities will follow the respective data retention policies of each of these institutions. Information relayed through communications between users and our partners (for instance pharmacy, lab, insurance and/or hospital partners and/or driver partner in delivering medicines), made other than through the use of our Services (such as by telephone calls, SMS, mobile messaging or other method of communication and collection of your Personal Data by our partner) may also be retained by some means. We do not encourage the retention of Personal Data 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 Data. 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 Data.

VIII. Erasure and Delisting of Personal Data

In accordance with the applicable laws and regulations, upon your written request, we may delete (right to erasure) and/or destroy your Personal Data from the system (right to delisting) so that the data no longer identifies you, except in the case of:

1. If we need to store Personal Data to fulfil legal, tax, audit, and/or accounting obligations, we will store the necessary Personal Data as long as you are still using our Services or according to the period required by applicable laws;

2. Your Personal Data is still within the retention period pursuant to the applicable laws and regulations; and/or

3. For the purpose of destroying your Personal Data from the system (right to delisting), a court order is required which is submitted by you so that we can destroy your irrelevant Personal Data from the list of search engines under our management.

IX. Your Rights over Personal Data

1. You may access and modify your Personal Data including email address, phone number, and date of birth directly when using our Services.

2. Insofar as it does not run in conflict with the provisions of the applicable laws and regulations, you may contact us to withdraw your consent to the utilization of your Personal Data in accordance with this Privacy Policy. In such circumstances, you understand the consequences that you may not use our Services.

3. You have the right to access or correct your Personal Data which is under our control by contacting the communication channels available under this Privacy Policy. However, the application will only be processed by us if you have submitted sufficient proof of identity to access or correct the data. We reserve the right to refuse requests to access, or to correct, some or all of your Personal Data that we own or control if permitted or required under applicable laws. This includes circumstances where the Personal Data may contain references to others or where a request for access or a request for correction is for reasons that we deem irrelevant, not serious or renders difficult. We may charge you an administrative fee for handling your request to access or correct your Personal Data.

X. Security of Your Personal Data

1. The confidentiality of your Personal Data is of utmost importance to us. We guarantee that the data and information provided by you is confidential and will not be shared, except for the matters that have been stated and agreed by you in this Privacy Policy. We apply our best efforts to protect and secure your Personal Data from access to collection, processing, analysis, storage, disclosure, amendment and deletion by unauthorized parties in the form of physical, electronic, and managerial security measures.

2. Although we use our best efforts to secure and protect your Personal Data, please note that data transmission over the Internet is never completely secure. Thus, we cannot guarantee 100% security of the data provided or sent to us by you and the provision of information by you is at your own risk. If we experience a data breach related to your Personal Data, to the extent required by applicable laws and regulations, we will notify you through our official channel, either directly or indirectly, to provide you with sufficient information regarding the data breach and will work to safeguard against misuse of your Personal Data.

3. You are responsible for maintaining the confidentiality of your account details, including telephone number, email, password (as applicable), and one-time passcode (OTP) with anyone and must always maintain and be responsible for the security of the devices you use. You will indemnify us from any loss or claims in the event that you are negligent in maintaining the confidentiality of your account details, including your password, email or one-time passcode (OTP), as well as in the event that you are negligent in maintaining the security of the device you are using.

XI. Governing Law

This Privacy Policy is governed by the laws of the Republic of Indonesia and You are required to comply with all applicable regulations in the Republic of Indonesia.

XII. Changes on Privacy Policy

We may amend, delete and apply new terms in this Privacy Policy. You are expected to check this Privacy Policy page periodically for any changes. By using our Services after such changes occur, you are deemed to have known and agreed to the changes to the terms of this Privacy Policy.

This Privacy Policy may be amended and/or updated from time to time, with the aim of ensuring this Privacy Policy is in accordance with business developments and/or legal developments that take place. In this regard, we may notify you of the amendment and/or updates in accordance with the provisions of the applicable laws and regulations. By continuing to access our Services, you are deemed to have read, understood and agreed to this Privacy Policy, including any changes and/or updates thereof from time to time.

XIII. Contact Us

If you have any questions, comments, complaints, or claims relating to this Privacy Policy or you want to gain access and/or make corrections to your Personal Data, please send us an email at support@modernvet.co.

PRIVACY POLICY