This Privacy Policy constitutes a real commitment from COKOLADOVNA (hereinafter referred to as “ COKOLADOVNA “) to respect and protect all personal data or information of the User (as defined in the Terms and Conditions) http://www.cokoladovna.com/ site, its microsites, and mobile applications of COKOLADOVNA (hereafter referred to as “Site”).

This Privacy Policy (including the terms of use of COKOLADOVNA site as set out in the Terms & Conditions and other information provided on the Site) sets forth the basis for the obtainment, collection, processing, analysis, display, transfer, opening, storage, modification, removal and/or any form of management in relation to any data or information, which identifies or may be used to identify a User that is provided by the User to COKOLADOVNA or collected by COKOLADOVNA from the User or any third party (hereinafter referred to as “Personal Data”).

By clicking “Register” or any similar statement available on the Site registration page, the User represents that every Personal Data of the User is true and valid data, the User acknowledges that the User has been notified and understands the terms of this Privacy Policy and the User grants consent to COKOLADOVNA to obtain, collect, process, analyze, display, transfer, open, store, modify, remove and/or use the data for the purposes as set out in the Privacy Policy. The Privacy Policy is written in both Bahasa Indonesia and English language. In case of conflict or discrepancies between both languages, the Bahasa Indonesia version will shall prevail.

A. Obtainment and Collection of Users’ Personal Data

B. Use of Users’ Personal Data

C. Disclosure and Transfer of Users’ Personal Data

D. Cookies

E. User Selection and Transparency

F. Security, Storage and Removal of Users’ Personal Data

G. Access and Correction of Users’ Personal Data or Consent Withdrawal

H. Complaints related to Protection of Users’ Personal Data

I. Contact Us

J. Privacy Policy Update

A. Obtainment and Collection of Users’ Personal Data

COKOLADOVNA collects Users’ Personal Data for the purpose of processing User transactions, managing and ease the process of using the Site as described in this Privacy Policy, and for other purposes insofar permissible under the applicable laws and regulations. The collected Users’ Personal Data are as follows:

  1. Data provided independently by the User, including but not limited to data provided at the time the User:
    1. creates or updates the COKOLADOVNA account, including among others username, email address, telephone number, password, address, photos and other identifiable information of the User;
    2. contacts COKOLADOVNA, including through customer service;
    3. fills out a survey sent by COKOLADOVNA or other parties officially appointed to represent COKOLADOVNA;
    4. interacts with other Users through messaging feature, product discussion, review, rating, Resolution Center (as defined in the Terms and Conditions) and other interactive features (whether one or two way) available on the Site;
    5. uses services on the Site, including detailed transactions data, among others the type, number and/or description of products or services being purchased, shipping address, payment channel being used, number of transactions, date and time of transaction, as well as other transaction details;
    6. fills in payment data at the time the User conducts a payment transaction activity through the Site, including but not limited to bank account data, credit card, electronic money/wallet, virtual account, instant payment, internet banking, retail stores; and/or
    7. uses features on the Site which require access permission to the relevant data stored in the User’s device.
  2. Data stored at the time the User uses the Site, including but not limited to:
    1. real or approximate location data such as IP address, Wi-Fi location and geo-location;
    2. data in the form of the time of every activity of a User in relation to the use of Site, including the time of registration, login and transaction;
    3. User usage or preference data, including User interactions in using the Site, saved selection, and selected setting. The data is obtained using cookies, pixel tags and similar technologies that create and maintain a unique identifier;
    4. device data, among others the device type used to access the Site, including hardware model, operating system and its version, software, IMEI number, file name and its version, language selection, unique device identifier, advertising identifier, serial number, device movement information, and/or cellular network information; and/or
    5. log data, including logs on server receiving the data such as device IP address, access date and time, application features or pages viewed, application work process and other system activities, browser type, and/or third party sites or services used by the User before interacting with the Site.
  3. Data obtained from other sources, including but not limited to:
    1. data in the form of geo-location (GPS) from COKOLADOVNA’s business partners that help COKOLADOVNA in developing and offering services on the Site to Users, among others payment service providers, logistics or couriers, site infrastructure partners and other partners.
    2. data in the form of email, telephone number, name, gender, and/or date of birth of COKOLADOVNA’s business partners where the User creates or accesses the COKOLADOVNA account, such as social media services, or sites/applications that use the application programming interface (API) of COKOLADOVNA or those used by COKOLADOVNA;
    3. data from financial service providers, including but not limited to credit rating agencies or bureaus or Credit Information Management Institutions (Lembaga Pengelola Informasi Perkreditan or LPIP);
    4. data from financial service providers (if the User uses specific features such as applying for a loan through COKOLADOVNA Site/Application); and/or
    5. data in the form of email from marketing service providers.

B. Use of Users’ Personal Data

COKOLADOVNA may use the Personal Data obtained and collected from Users as provided in the previous section for the following purposes:

  1. Processing of all forms of requests, activities and transactions made by Users through the Site, including for the purpose of delivering products to Users.
  2. Provision of features to provide, create, maintain and improve COKOLADOVNA products and services, including:
    1. to offer, obtain, provide, or facilitate marketplace services such as home page, browsing, search, advertisements, product recommendations, COKOLADOVNA Feed, insurance, financing, loans, or other products through the Site;
    2. to enable features to personalize the User’s COKOLADOVNA account, such as Shopping Cart, Wishlist and Favorite Stores; and/or
    3. to carry out internal activities necessary to provide services on COKOLADOVNA site/application, such as solving software issues, bug, operational issues, conducting data analysis, testing, and research, and to monitor and analyze usage trends and activities.
  3. Assisting Users when communicating with COKOLADOVNA customer service, including to:
    1. check and resolve User problems;
    2. direct Users’ questions to the appropriate customer service officer in order to resolve the problem;
    3. monitor and improve COKOLADOVNA’s customer service responses;
    4. contact Users by email, letter, telephone, facsimile and other communication methods, including but not limited to assisting and/or completing transaction process or problem resolution process, and to deliver news or other notifications in relation to the protection of Users’ Personal Data by COKOLADOVNA, including the failure to protect the Users’ Personal Data;
    5. use information obtained from Users for the purpose of research, analysis, development and testing of products in order to improve the security of the services on the Site, as well as develop new features and products; and
    6. inform Users in relation to products, services, promotion, studies, survey, news, latest update, events and other information, either through the Site or through other media. COKOLADOVNA may also use such information to promote and process contests and sweepstakes, award prizes, and serve relevant ads and contents regarding the services of COKOLADOVNA and its business partners.
  4. Monitoring and investigating suspicious transactions or transactions indicated to contain elements of fraud or violation of the Terms and Conditions or applicable legal provisions, as well as taking the necessary actions as a follow-up to the results of the monitoring or investigation of such transactions.
  5. In certain event, COKOLADOVNA may be required to use or disclose the User’s Personal Data for the purpose of law enforcement or to fulfill the requirement and obligation under the applicable laws and regulations, including in the event of a dispute or legal process between a User and COKOLADOVNA, or alleged criminal offence such as fraud or data theft.
  6. Facilitating transactions of merger, sales of company’s assets, consolidation or restructuring, financing or acquisition involving COKOLADOVNA.

C. Disclosure and Transfer of Users’ Personal Data

  1. COKOLADOVNA is committed to maintain the confidentiality of the User’s Personal Data which is under COKOLADOVNA’s control and warrants that there is no disclosure, sale, transfer, distribution and/or borrowing of the User’s Personal Data to other third parties, without the consent of the User, except in the following cases:
    1. it is required to disclose the User’s Personal Data to partners or other third parties assisting COKOLADOVNA in providing services that are available or services that will later be available on the Site and in processing all forms of the User’s activities on the Site, including processing transactions, verification of payments, promotions, and product delivery.
    2. COKOLADOVNA may provide Personal Data to business partners in accordance with the User’s consent to use the business partner’s services, including among others other applications or sites that have integrated their APIs or services with each other, or business partners that have cooperated with COKOLADOVNA to organize promotions, competitions, or special services available on the Site, such as the Trade-In (Tukar Tambah) or Immediately Sold (Langsung Laku) program organized by COKOLADOVNA.
    3. COKOLADOVNA may provide the User’s Personal Data to third parties that use and integrate the public API provided by COKOLADOVNA (including but not limited to COKOLADOVNA’s business partner service providers) with the applications or sites operated by such third parties for the purpose of settling transactions between Buyers and Sellers on the Site or other purposes of using the Personal Data as described in Section B of this Privacy Policy.
    4. there is a need for communication between COKOLADOVNA’s business partners (such as logistic providers, payment providers, and feature providers or other service facilities) and the User in resolving problems or other matters.
    5. COKOLADOVNA may provide the Users’ Personal Data to vendors, consultants, marketing partners, research firms/agencies, or similar service providers for the purpose of marketing activities conducted by third parties, improvement and maintenance of the quality of COKOLADOVNA’s services, as well as other publication activities.
    6. When the User contact COKOLADOVNA through public media such as blog, social media, and certain features on the Site, where the communication between the User and COKOLADOVNA can be viewed and known by the public.
    7. COKOLADOVNA may share Users’ Personal Data to its subsidiary and affiliate to assist the provision of service or conduct data processing for and on behalf of COKOLADOVNA.
    8. COKOLADOVNA may disclose and/or provide Users’ Personal Data to interested parties for the purpose of conducting creditworthiness analysis.
    9. COKOLADOVNA shall disclose Users’ Personal Data in an effort to comply with legal obligations and/or official request from law enforcement or authorized state agencies.
  2. In relation to the disclosure of Users’ Personal Data as described above, COKOLADOVNA will/may be required to disclose Users’ Personal Data to third party service providers, agents and/or affiliates or relevant companies of COKOLADOVNA, and/or other third parties located outside the territory of Indonesia. However, such third party service providers, agents and/or affiliates or relevant companies and/or other third parties shall only manage and/or utilize Users’ Personal Data in connection with one or more purposes as set out in this Privacy Policy and in accordance with the provisions of the applicable laws and regulations.

D. Cookies

  1. Cookies mean small files that will automatically take place on the User’s device which performs the function of storing User preferences and configurations while visiting a site.
  2. Cookies are not intended to be used when accessing other data that the User has on the User’s computer device, other than what the User has agreed to submit.
  3. Although the User’s computer device will automatically accept cookies, the User may choose to make modifications through the User’s browser setting, namely by choosing to reject cookies (this option may hinder the optimal availability of COKOLADOVNA’s services when the User accesses the Site).
  4. COKOLADOVNA is using Google Analytics Demographics and Interest features. Data obtained by COKOLADOVNA from such features, such as age, gender, User’s interest and other identifiable information of the User, will be used by COKOLADOVNA for the development of features, facilities and/or contents available on COKOLADOVNA Site. If the User does not wish for Google Analytics to track the User’s data, the User may use Add-On Google Analytics Opt-Out Browser.
  5. COKOLADOVNA may use the features provided by third parties for the purpose of improving COKOLADOVNA’s services and contents, including the assessment, adjustment and serving of advertisements to every User based on their interest or visit history. If the User does not wish for any advertisement to be displayed based on such adjustment, the User may set it via browser.

E. User Selection and Transparency

  1. Mobile devices in general (iOS and Android) have settings so that the COKOLADOVNA application cannot access certain data without the consent of the User. The iOS device will notify the User when the COKOLADOVNA application first requests access to the data, while the Android device will notify the User when the COKOLADOVNA application is first installed. By using the application and providing access to the application, the User is deemed to have given his/her consent to the collection and use of the User’s Personal Data on his/her device.
  2. After a successful sale and purchase transaction on the Site, the Seller and the Buyer (as defined in the Terms and Conditions) have the opportunity to rate and review one another. This information may be publicly viewable with the User’s consent.
  3. Users may access and modify information in the form of email address, telephone number, date of birth, gender, address list, payment method, and bank account through settings feature on the Site.
  4. Users may opt-out from information or notifications in the form of newsletters, reviews, product discussions, private messages, or private messages from the Admin sent by COKOLADOVNA through the settings feature on the Site. COKOLADOVNA may still send messages or emails in the form of transaction information or information related to the User’s account.
  5. Insofar not in contradiction with the provisions of the applicable laws and regulations, the User may contact COKOLADOVNA to withdraw the consent for the obtainment, collection, storage, management and use of the User’s data. In such event, the User understands the consequence that the User may no longer use the services of the Site and other COKOLADOVNA’s services.

F. Security, Storage and Removal of Users’ Personal Data

  1. COKOLADOVNA protects every User’s Personal Data stored in its system, and protect such data from any unauthorized access, use, modification, collection and/or disclosure by using a number of security measures and procedures, including password and OTP (One Time Password) code of the User.
  2. Users’ Personal Data may also be stored or processed abroad by parties working with COKOLADOVNA in other countries, or by third party service providers, vendors, suppliers, partners, contractors, or affiliates of COKOLADOVNA. In such event, COKOLADOVNA shall ensure that the Personal Data remains protected pursuant to COKOLADOVNA’s commitment in this Privacy Policy.
  3. Even though COKOLADOVNA has used its best effort to secure and protect the Users’ Personal Data, it should be noted that data transmission over the Internet is never fully secured. Therefore, COKOLADOVNA is unable to guarantee 100% the security of the data provided or transmitted to COKOLADOVNA by the User and the provision of information by the User shall be at the User’s own risk.
  4. COKOLADOVNA shall delete and/or anonymize the User’s Personal Data that is under COKOLADOVNA’s control in the event (i) the User’s Personal Data is no longer required to fulfill the purpose of its collection; and (ii) retention is no longer required for the purpose of compliance with the applicable laws and regulations.
  5. Please note that there remains a possibility that some Personal Data of the User is stored by other parties, including the authorized state agencies. In the event that we share the User’s Personal Data with the authorized state agencies and/or other agencies that may be appointed by the authorized government or having cooperation with COKOLADOVNA, the User agrees and acknowledges that the retention of the User’s Personal Data by such agency will follow the data retention policy of each agency.

G. Access and Correction of Users’ Personal Data or Consent Withdrawal

  1. COKOLADOVNA shall take reasonable measures to ensure that the User’s Personal Data is processed accurately and completely. However, it is important for the User to promptly notify COKOLADOVNA of any change in the User’s Personal Data or in the event of any inaccuracy of the User’s Personal Data that is under COKOLADOVNA’s control.
  2. The User shall be entitled to access or correct the User’s Personal Data that is under COKOLADOVNA’s control via COKOLADOVNA customer service available in this Privacy Policy. However, such request shall only be processed by COKOLADOVNA if the User has submitted sufficient proof of identity to access or correct the data. COKOLADOVNA reserves the right to refuse the request to access, or to correct, part or all of the User’s Personal Data owned or controlled by COKOLADOVNA insofar permitted or required under the applicable laws and regulations. This includes circumstances where the Personal Data may contain references to other people or where the request for access or request for correction is for reasons that is deemed irrelevant, not serious, or difficult by COKOLADOVNA.
  3. COKOLADOVNA may charge administration fees to the User to handle the User’s request for access or correction of the User’s Personal Data.
  4. The User may withdraw the consent granted by the User in relation to the processing of the User’s Personal Data that is under COKOLADOVNA’s control by submitting such request through COKOLADOVNA customer service provided in this Privacy Policy. COKOLADOVNA shall process the User’s request within a reasonable period of time as of the submission of the consent withdrawal request, and shall not further process the User’s Personal Data pursuant to the User’s initial request, unless required by the applicable laws and regulations. In the event of a consent withdrawal, COKOLADOVNA may no longer able to perform its obligations based on any agreement between the User and COKOLADOVNA. In this regard, there is also a possibility that since COKOLADOVNA is no longer able to perform its obligations due to the withdrawal of consent by the User, any legal relationship between the User and COKOLADOVNA would terminate and cannot be continued.

H. Complaints related to Protection of Users’ Personal Data

  1. If the User has any concern with regard to the handling or treatment of COKOLADOVNA to the User’s Personal Data or if the User believes that the User’s privacy has been breached, the User may contact COKOLADOVNA through COKOLADOVNA customer service or to the COKOLADOVNA’s contact provided in this Privacy Policy by describing the identity and nature of complaint of the User.
  2. COKOLADOVNA shall investigate the User’s complaint and attempt to provide a response to such complaint within a reasonable period of time after receiving the complaint submitted by the User.

I. Contact Us

If the User has any question, comment, complaint, or claim regarding this Privacy Policy or the User wishes to obtain access and/or make correction to the User’s Personal Data, please contact COKOLADOVNA customer service through http://www.cokoladovna.com/contact page.

Privacy Policy Update

COKOLADOVNA may at any time amend or update this Privacy Policy. COKOLADOVNA advises the User to carefully read and check this Privacy Policy page from time to time to be aware of any amendment. By remain accessing and using the services of the Site or other COKOLADOVNA’s services, the User is deemed to agree to the amendments in this Privacy Policy.