PRIVACY POLICY

Last updated July 26, 2023

This privacy notice for PT Menara Sinar Semesta ("we," "us," or "our"), describeshow and why we might collect, store, use, and/or share ("process") your informationwhen you use our services ("Services"), such as when you:

• Visit our website at https://cloudku.id, or any website of ours that links to thisprivacy notice
• Engage with us in other related ways, including any sales, marketing, orevents

Questions or concerns? Reading this privacy notice will help you understand yourprivacy rights and choices. If you do not agree with our policies and practices, pleasedo not use our Services. If you still have any questions or concerns, please contactus at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can findout more details about any of these topics by clicking the link following eachkey point or by using our table of contents below to find the section you arelooking for.

What personal information do we process? When you visit, use, or navigate ourServices, we may process personal information depending on how you interact withus and the Services, the choices you make, and the products and features you use.Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We may process sensitivepersonal information when necessary with your consent or as otherwise permitted byapplicable law. Learn more about sensitive information we process.

Do we receive any information from third parties? We do not receive anyinformation from third parties.

How do we process your information? We process your information to provide,improve, and administer our Services, communicate with you, for security and fraudprevention, and to comply with law. We may also process your information for otherpurposes with your consent. We process your information only when we have a validlegal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information?We may share information in specific situations and with specific third parties. Learnmore about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technicalprocesses and procedures in place to protect your personal information. However, noelectronic transmission over the internet or information storage technology can beguaranteed to be 100% secure, so we cannot promise or guarantee that hackers,cybercriminals, or other unauthorized third parties will not be able to defeat oursecurity and improperly collect, access, steal, or modify your information. Learn moreabout how we keep your information safe.

What are your rights? Depending on where you are located geographically, theapplicable privacy law may mean you have certain rights regarding your personalinformation. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is bysubmitting a data subject access request, or by contacting us. We will consider andact upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review theprivacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO WE MAKE UPDATES TO THIS NOTICE?
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECTFROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you registeron the Services, express an interest in obtaining information about us or our productsand Services, when you participate in activities on the Services, or otherwise whenyou contact us.

Personal Information Provided by You. The personal information that we collectdepends on the context of your interactions with us and the Services, the choices youmake, and the products and features you use. The personal information we collectmay include the following:

• names
• phone numbers
• email addresses
• mailing addresses
• job titles
• usernames
• passwords
• contact preferences
• contact or authentication data
• billing addresses
• debit/credit card numbers

Sensitive Information. When necessary, with your consent or as otherwisepermitted by applicable law, we process the following categories of sensitiveinformation:

Payment Data. We may collect data necessary to process your payment if you makepurchases, such as your payment instrument number, and the security codeassociated with your payment instrument. All payment data is stored by DUITKU andPaypal. You may find their privacy notice link(s) here:https://www.duitku.com/kebijakan-privasi/ and https://www.paypal.com/id/legalhub/privacy-full.

All personal information that you provide to us must be true, complete, and accurate,and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/orbrowser and device characteristics — is collected automatically when you visit ourServices.

We automatically collect certain information when you visit, use, or navigate theServices. This information does not reveal your specific identity (like your name orcontact information) but may include device and usage information, such as your IPaddress, browser and device characteristics, operating system, languagepreferences, referring URLs, device name, country, location, information about howand when you use our Services, and other technical information. This information isprimarily needed to maintain the security and operation of our Services, and for ourinternal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic,usage, and performance information our servers automatically collect whenyou access or use our Services and which we record in log files. Depending onhow you interact with us, this log data may include your IP address, deviceinformation, browser type, and settings and information about your activity inthe Services (such as the date/time stamps associated with your usage, pagesand files viewed, searches, and other actions you take such as which featuresyou use), device event information (such as system activity, error reports(sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer,phone, tablet, or other device you use to access the Services. Depending onthe device used, this device data may include information such as your IPaddress (or proxy server), device and application identification numbers,location, browser type, hardware model, Internet service provider and/ormobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about yourdevice's location, which can be either precise or imprecise. How muchinformation we collect depends on the type and settings of the device you useto access the Services. For example, we may use GPS and other technologiesto collect geolocation data that tells us your current location (based on your IPaddress). You can opt out of allowing us to collect this information either byrefusing access to the information or by disabling your Location setting on yourdevice. However, if you choose to opt out, you may not be able to use certainaspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer ourServices, communicate with you, for security and fraud prevention, and to complywith law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending onhow you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manageuser accounts. We may process your information so you can create and login to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may processyour information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process yourinformation to respond to your inquiries and solve any potential issues youmight have with the requested service.
• To send administrative information to you. We may process yourinformation to send you details about our products and services, changes toour terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfilland manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We may process your informationif you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary torequest feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We mayprocess the personal information you send to us for our marketing purposes, ifthis is in accordance with your marketing preferences. You can opt out of ourmarketing emails at any time. For more information, see "WHAT ARE YOURPRIVACY RIGHTS?" below.
• To deliver targeted advertising to you. We may process your information todevelop and display personalized content and advertising tailored to yourinterests, location, and more.
• To post testimonials. We post testimonials on our Services that may containpersonal information.
• To protect our Services. We may process your information as part of ourefforts to keep our Services safe and secure, including fraud monitoring andprevention.
• To administer prize draws and competitions. We may process yourinformation to administer prize draws and competitions.
• To evaluate and improve our Services, products, marketing, and yourexperience. We may process your information when we believe it isnecessary to identify usage trends, determine the effectiveness of ourpromotional campaigns, and to evaluate and improve our Services, products,marketing, and your experience.
• To identify usage trends. We may process information about how you useour Services to better understand how they are being used so we can improvethem.
• To determine the effectiveness of our marketing and promotionalcampaigns. We may process your information to better understand how toprovide marketing and promotional campaigns that are most relevant to you.
• To comply with our legal obligations. We may process your information tocomply with our legal obligations, respond to legal requests, and exercise,establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOURPERSONAL INFORMATION?

In Short: We may share information in specific situations described in this sectionand/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connectionwith, or during negotiations of, any merger, sale of company assets, financing,or acquisition of all or a portion of our business to another company.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and storeyour information.

We may use cookies and similar tracking technologies (like web beacons and pixels)to access or store information. Specific information about how we use suchtechnologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposesoutlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for thepurposes set out in this privacy notice, unless a longer retention period is required orpermitted by law (such as tax, accounting, or other legal requirements). No purposein this notice will require us keeping your personal information for longer than theperiod of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personalinformation, we will either delete or anonymize such information, or, if this is notpossible (for example, because your personal information has been stored in backuparchives), then we will securely store your personal information and isolate it fromany further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system oforganizational and technical security measures.

We have implemented appropriate and reasonable technical and organizationalsecurity measures designed to protect the security of any personal information weprocess. However, despite our safeguards and efforts to secure your information, noelectronic transmission over the Internet or information storage technology can beguaranteed to be 100% secure, so we cannot promise or guarantee that hackers,cybercriminals, or other unauthorized third parties will not be able to defeat oursecurity and improperly collect, access, steal, or modify your information. Althoughwe will do our best to protect your personal information, transmission of personalinformation to and from our Services is at your own risk. You should only access theServices within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 yearsof age.

We do not knowingly solicit data from or market to children under 18 years of age. Byusing the Services, you represent that you are at least 18 or that you are the parentor guardian of such a minor and consent to such minor dependent’s use of theServices. If we learn that personal information from users less than 18 years of agehas been collected, we will deactivate the account and take reasonable measures topromptly delete such data from our records. If you become aware of any data wemay have collected from children under age 18, please contact us [email protected].

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

Withdrawing your consent: If we are relying on your consent to process yourpersonal information, which may be express and/or implied consent depending onthe applicable law, you have the right to withdraw your consent at any time. You canwithdraw your consent at any time by contacting us by using the contact detailsprovided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"below.

However, please note that this will not affect the lawfulness of the processing beforeits withdrawal nor, when applicable law allows, will it affect the processing of yourpersonal information conducted in reliance on lawful processing grounds other thanconsent.

Opting out of marketing and promotional communications: You can unsubscribefrom our marketing and promotional communications at any time by clicking on theunsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" tothe SMS messages that we send, or by contacting us using the details provided inthe section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You willthen be removed from the marketing lists. However, we may still communicate withyou — for example, to send you service-related messages that are necessary for theadministration and use of your account, to respond to service requests, or for othernon-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account orterminate your account, you can:

Contact us using the contact information provided.

• https://support.cloudku.id/en
• Email [email protected]
• Visit https://cloudku.contact
• Log in to your account settings and update your user account.
• https://manage.cloudku.id

Upon your request to terminate your account, we will deactivate or delete youraccount and information from our active databases. However, we may retain someinformation in our files to prevent fraud, troubleshoot problems, assist with anyinvestigations, enforce our legal terms and/or comply with applicable legalrequirements.

Cookies and similar technologies: Most Web browsers are set to accept cookiesby default. If you prefer, you can usually choose to set your browser to removecookies and to reject cookies. If you choose to remove cookies or reject cookies, thiscould affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us [email protected].

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applicationsinclude a Do-Not-Track ("DNT") feature or setting you can activate to signal yourprivacy preference not to have data about your online browsing activities monitoredand collected. At this stage no uniform technology standard for recognizing andimplementing DNT signals has been finalized. As such, we do not currently respondto DNT browser signals or any other mechanism that automatically communicatesyour choice not to be tracked online. If a standard for online tracking is adopted thatwe must follow in the future, we will inform you about that practice in a revisedversion of this privacy notice.

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevantlaws.

We may update this privacy notice from time to time. The updated version will beindicated by an updated "Revised" date and the updated version will be effective assoon as it is accessible. If we make material changes to this privacy notice, we maynotify you either by prominently posting a notice of such changes or by directlysending you a notification. We encourage you to review this privacy notice frequentlyto be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us [email protected] or contact us by post at:

PT Menara Sinar Semesta

Koala Regency D20 Semolo Bahari

Surabaya, Jawa Timur 60119

Indonesia

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THEDATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to requestaccess to the personal information we collect from you, change that information, ordelete it. To request to review, update, or delete your personal information, please fillout and submit a data subject access request.