IDAFF.COM PRIVACY POLICY
LAST UPDATED: May 25, 2018

INTRODUCTION

This privacy policy (“Policy”) describes how IDAFF.COM,
PT. VINAYA SUKSES ABADI (“Company,” “we,” and “our”)
processes, collects, uses and shares personal data
when using this website IDAFF.COM (the “Site”).

Please read the following information carefully to
understand our practices regarding your personal data
and how we will process data.

1. PURPOSES OF PROCESSING
What is personal data?
We collect information about you in a range of forms,
including personal data. As used in this Policy,
“personal data” is as defined in the General Data
Protection Regulation, this includes any information
which, either alone or in combination with other
information we process about you, identifies you as an
individual, including, for example, your name, postal
address, email address and telephone number.
Why do we need your personal data?
We will only process your personal data in accordance
with applicable data protection and privacy laws. We
need certain personal data in order to provide you with
access to the Site. If you registered with us, you will
have been asked to tick to agree to provide this
information in order to access our services, purchase
our products, or view our content. This consent
provides us with the legal basis we require under
applicable law to process your data. You maintain the
right to withdraw such consent at any time. If you do
not agree to our use of your personal data in line with
this Policy, please do not use our Site.

2. COLLECTING YOUR PERSONAL DATA
We collect information about you in the following ways:
Information You Give Us. This includes:
• the personal data you provide when you register to
use our Site, including your‎ name, postal address,
email address, telephone number, username, password and
demographic information (such as your gender); [Note:
Please confirm what information users will be required
to submit when they register.]
• the personal data that may be contained in any
video, comment or other submission you upload or post
to the Site; [Note: What content can users post to the
Site? – if no content, please delete this paragraph]
• the personal data you provide in connection with
our rewards program and other promotions we run on the
Site;
• the personal data you provide when you report a
problem with our Site or when we provide you with
customer support;
• the personal data you provide when you make a
purchase thorough our Site; and
• the personal data you provide when you correspond
with us by phone, email or otherwise.

[Information from Social Networking Sites. Our Site
include interfaces that allow you to connect with
social networking sites (each a “SNS”). If you connect
to a SNS through our Site, you authorize us to access,
use and store the information that you agreed the SNS
could provide to us based on your settings on that SNS.

We will access, use and store that information in
accordance with this Policy. You can revoke our access
to the information you provide in this way at any time
by amending the appropriate settings from within your
account settings on the applicable SNS.]

[Information Automatically Collected. We automatically
log information about you and your computer or mobile
device when you access our Site. For example, when
visiting our Site, we log your computer or mobile
device operating system name and version, manufacturer
and model, browser type, browser language, screen
resolution, the website you visited before browsing to
our Site, pages you viewed, how long you spent on a
page, access times and information about your use of
and actions on our Site. We collect this
information about you using cookies.

Automated Decision Making and Profiling.
We do not use your personal data for the purposes of
automated decision-making. However, we may do so in
order to fulfil obligations imposed by law, in which
case we will inform you of any such processing and
provide you with an opportunity to object.

3. COOKIES
What are cookies?
We may collect information using “cookies.” Cookies are
small data files stored on the hard drive of your
computer or mobile device by a website. We may use both
session cookies (which expire once you close your web
browser) and persistent cookies (which stay on your
computer or mobile device until you delete them) to
provide you with a more personal and interactive
experience on our Site.

We use two broad categories of cookies: (1) first party
cookies, served directly by us to your computer or
mobile device, which are used only by us to recognize
your computer or mobile device when it revisits our
Site; and (2) third party cookies, which are served by
service providers on our Site, and can be used by such
service providers to recognize your computer or mobile
device when it visits other websites.

Cookies we use
Our Site uses the following types of cookies for the
purposes set out below: [Note: Please review the
following table and amend it as necessary so that it
accurately describes the types of cookies that will be
used on the Site and the purposes for which they will
be used. Please note that for the EU, you will also
need to implement a cookie banner or otherwise obtain
the consent of EU Data Subjects to the cookie policy.]

Type of cookie Purpose
Essential Cookies These cookies are essential to
provide you with services available through our Site
and to enable you to use some of its features. [For
example, they allow you to log in to secure areas of
our Site and help the content of the pages you request
load quickly]. [Note: Is this bracketed wording
correct?] Without these cookies, the services that you
have asked for cannot be provided, and we only use
these cookies to provide you with those services.
Functionality Cookies These cookies allow our Site
to remember choices you make when you use our Site,
[such as remembering your language preferences,
remembering your login details and remembering the
changes you make to other parts of our Site which you
can customize.

The purpose of these cookies is to provide
you with a more personal experience and to avoid you
having to re-enter your preferences every time you
visit our Site.

Analytics and Performance Cookies

These cookies are used to collect information about
traffic to our Site and how users use our Site.

The information gathered does not identify any
individual visitor. [It includes the number of visitors
to our Site, the websites that referred them to our Site,
the pages they visited on our Site, what time of day
they visited our Site, whether they have visited our
Site before, and other similar information.]

[We use this information to help
operate our Site more efficiently, to gather broad
demographic information and to monitor the level of
activity on our Site.]

[We use Google Analytics for this purpose. Google
Analytics uses its own cookies. It is only used to
improve how our Site works. You can find out more
information about Google Analytics cookies here:
https://developers.google.com/analytics/resources/
concepts/gaConceptsCookies]

[You can find out more about how Google protects your
data here:
www.google.com/analytics/learn/privacy.html.]

[You can prevent the use of Google Analytics relating
to your use of our Site by downloading and installing
the browser plugin available via this link:
http://tools.google.com/dlpage/gaoptout?hl=en-GB]

Targeted and advertising cookies [These cookies
track your browsing habits to enable us to show
advertising which is more likely to be of interest to
you. These cookies use information about your browsing
history to group you with other users who have similar
interests. Based on that information, and with our
permission, third party advertisers can place cookies
to enable them to show adverts which we think will be
relevant to your interests while you are on third party
websites.] [Note: Is this applicable? Will there be
third party behavioral advertising on the Site?]

[You can disable cookies which remember your browsing
habits and target advertising at you by visiting
http://www.youronlinechoices.com/uk/your-ad-choices. If
you choose to remove targeted or advertising cookies,
you will still see adverts but they may not be relevant
to you. Even if you do choose to remove cookies by the
companies listed at the above link, not all companies
that serve online behavioral advertising are included
in this list, and so you may still receive some cookies
and tailored adverts from companies that are not
listed.]

Social Media Cookies [These cookies are used when
you share information using a social media sharing
button or “like” button on our Site or you link your
account or engage with our content on or through a
social networking website such as Facebook, Twitter or
Google+. The social network will record that you have
done this.]

Disabling cookies
You can typically remove or reject cookies via your
browser settings. In order to do this, follow the
instructions provided by your browser (usually located
within the “settings,” “help” “tools” or “edit”
facility). Many browsers are set to accept cookies
until you change your settings.
If you do not accept our cookies, you may experience
some inconvenience in your use of our Site. For
example, we may not be able to recognize your computer
or mobile device and you may need to log in every time
you visit our Site.

4. ADVERTISING
We may use other companies to serve third-party
advertisements when you visit and use the Site. These
companies may collect and use click stream information,
browser type, time and date, subject of advertisements
clicked or scrolled over during your visits to the Site
and other websites in order to provide advertisements
about goods and services likely to be of interest to
you. These companies typically use tracking
technologies to collect this information. Other
companies' use of their tracking technologies is
subject to their own privacy policies.

5. USING YOUR PERSONAL DATA
We may use your personal data as follows:
• to operate, maintain, and improve our Site,
products, and services;
• to manage your account, including to communicate
with you regarding your account, if you have an account
on our Site;
• to operate and administer our rewards program and
other promotions you participate in on our Site;
• to respond to your comments and questions and to
provide customer service;
• to send information including technical notices,
updates, security alerts, and support and
administrative messages;
• with your consent, to send you marketing e-mails
about upcoming promotions, and other news, including
information about products and services offered by us
and our affiliates. You may opt-out of receiving such
information at any time: such marketing emails tell you
how to “opt-out.” Please note, even if you opt out of
receiving marketing emails, we may still send you
non-marketing emails. Non-marketing emails include
emails about your account with us (if you have one) and
our business dealings with you;
• [to process payments you make via our Site];
• as we believe necessary or appropriate (a) to
comply with applicable laws; (b) to comply with lawful
requests and legal process, including to respond to
requests from public and government authorities; (c) to
enforce our Policy; and (d) to protect our rights,
privacy, safety or property, and/or that of you or
others;
• for analysis and study services; and
• as described in the “Sharing of your Personal
Data” section below.
[Note: Please confirm whether the above list is correct
and whether there are any other purposes for which you
will use personal data.]

6. SHARING YOUR PERSONAL DATA
We may share your personal data as follows:
• Third Parties Designated by You. We may share your
personal data with third parties where you have
provided your consent to do so.
• Our Third Party Service Providers. We may share
your personal data with our third party service
providers who provide services such as [data analysis,
payment processing, information technology and related
infrastructure provision, customer service, email
delivery, auditing and other similar services].

7. THIRD PARTY SITES
Our Site may contain links to third party websites and
features. This Policy does not cover the privacy
practices of such third parties.
These third parties have their own privacy policies and
we do not accept any responsibility or liability for
their websites, features or policies.
Please read their privacy policies before you submit
any data to them.
[For example, Facebook like buttons, Facebook Connect,
Google +1 Button, Sign in with Google, Twitter widget,
etc.]

8. USER GENERATED CONTENT
You may share personal data with us when you submit
user generated content to our Site, [including via our
rewards program, forums, message boards and blogs on
our Site]. Please note that any information you post
or disclose on our Site will become public information,
and will be available to other users of our Site and
to the general public.

We urge you to be very careful when deciding to
disclose your personal data, or any other information,
on our Site. Such personal data and other information
will not be private or confidential once it is
published on our Site.

If you provide feedback to us, we may use and disclose
such feedback on our Site [, provided we do not
associate such feedback with your personal data]. [If
you have provided your consent to do so, we may post
your first and last name along with your feedback on
our Site.] [We will collect any information contained
in such feedback and will treat the personal data in it
in accordance with this Policy.]

9. INTERNATIONAL DATA TRANSFER
Your information, including personal data that we
collect from you, may be transferred to, stored at and
processed by us outside the country in which you
reside, where data protection and privacy regulations
may not offer the same level of protection as in other
parts of the world. By accepting this Policy, you agree
to this transfer, storing or processing. We will take
all steps reasonably necessary to ensure that your data
is treated securely and in accordance with this Policy.

10. SECURITY
We seek to use reasonable organizational, technical and
administrative measures to protect personal data within
our organization. Unfortunately, no transmission or
storage system can be guaranteed to be completely
secure, and transmission of information via the
internet is not completely secure. If you have reason
to believe that your interaction with us is no longer
secure (for example, if you feel that the security of
any account you might have with us has been
compromised), please immediately notify us of the
problem by contacting us.

11. RETENTION
We will only retain your personal data for [INSERT
RETENTION PERIOD/ESTIMATED RETENTION PERIOD AND METHOD
USED TO ESTIMATE RETENTION PERIOD unless a longer
retention period is required or permitted by law (for
example for regulatory purposes).
OR
We will only retain your personal data [as long
reasonably required for you to use the Site until you
close your account/cancel your subscription] unless a
longer retention period is required or permitted by law
(for example for regulatory purposes).

12. OUR POLICY ON CHILDREN
Our Site is/are not directed to children under 16. If a
parent or guardian becomes aware that his or her child
has provided us with information without their consent,
he or she should contact us. We will delete such
information from our files as soon as reasonably
practicable.

13. YOUR RIGHTS
• Opt-out. You may contact us anytime to opt-out of:
(i) direct marketing communications; (ii) automated
decision-making and/or profiling; (iii) our collection
of sensitive personal data; (iv) any new processing of
your personal data that we may carry out beyond the
original purpose; or (v) the transfer of your personal
data outside the EEA. Please note that your use of some
of the Site may be ineffective upon opt-out.
• Access. You may access the information we hold
about you at any time via your profile/account or by
contacting us directly.
• Amend. You can also contact us to update or
correct any inaccuracies in your personal data.
• Move. Your personal data is portable – i.e. you to
have the flexibility to move your data to other service
providers as you wish.
• Erase and forget. In certain situations, for
example when the information we hold about you is no
longer relevant or is incorrect, you can request that
we erase your data.
If you wish to exercise any of these rights, please
contact us. In your request, please make clear: (i)
what personal data is concerned; and (ii) which of the
above rights you would like to enforce. For your
protection, we may only implement requests with respect
to the personal data associated with the particular
email address that you use to send us your request, and
we may need to verify your identity before implementing
your request. We will try to comply with your request
as soon as reasonably practicable and in any event,
within one month of your request. Please note that we
may need to retain certain information for
recordkeeping purposes and/or to complete any
transactions that you began prior to requesting such
change or deletion.

14. COMPLAINTS
We are committed to resolve any complaints about our
collection or use of your personal data. If you would
like to make a complaint regarding this Policy or our
practices in relation to your personal data, please
contact us at: [email protected] We will reply to
your complaint as soon as we can and in any event, within
30 days. We hope to resolve any complaint brought to our
attention, however if you feel that your complaint has
not been adequately resolved, you reserve the right to
contact your local data protection supervisory
authority

15. CONTACT INFORMATION
We welcome your comments or questions about this
Policy. You may contact us in writing at [email protected]
or on our current address on contact page.

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