Privacy Policy

Latest Update : 24 April 2024 

Please carefully review this privacy policy in its entirety before providing consent and submitting your personal data to our services.

A. INTRODUCTION

Thank you for selecting PT Serasi Autoraya (“TRAC”) as your provider of vehicles rental services.

This Privacy Policy is established by PT Serasi Autoraya ("TRAC"), a limited liability company governed by the laws of the Republic of Indonesia, with its headquarters at GRHA SERA, Jalan Mitra Sunter Boulevard Kav. 90/C2, Sunter Jaya, Tanjung Priok, North Jakarta. It aims to safeguard the personal data (“Personal Data”) of users (“you”) utilizing TRAC applications, platforms, websites, and services (“TRAC Platform”), in compliance with applicable statutory regulations.

TRAC aims to ensure that you have the finest experience while utilizing the services we offer. To achieve this, TRAC seeks to gain a better understanding of you by storing and managing your Personal Data. Safeguarding the privacy and security of your Personal Data is of utmost importance to us. In this regard, we will transparently clarify how and why we collect, utilise, and disclose your Personal Data. This Privacy Policy delineates our commitments and obligations concerning the collection, usage, and disclosure of your Personal Data.

By using TRAC services, you affirm that you have reviewed and comprehended this Privacy Policy, thereby granting TRAC permission to collect, utilize, and disclose your Personal Data as outlined in this Privacy Policy.

You retain the right to revoke your consent for any or all instances of collecting, utilizing, and disclosing your Personal Data by giving TRAC appropriate written notice through the "Contact Us" section provided in this Privacy Policy.

Furthermore, you have the option to withdraw your consent for receiving specific communications and information from us by reaching out to us through the "Contact Us" section in this Privacy Policy. It is important to note that depending on the nature and context of the consent you withdraw, you acknowledge that such action will result in the inability to access the TRAC Platform.

Withdrawal of your consent may lead to the closure of your profile account associated with the TRAC Platform, or the termination of your contractual relationship with TRAC, with all corresponding rights and obligations subject to complete adherence. Upon receiving a notice to withdraw consent for the collection, use, or disclosure of your Personal Data, TRAC will duly inform you of the potential implications of such revocation so that you can make an informed decision on whether to proceed with the withdrawal.

B. ABOUT PRIVACY POLICY

This Privacy Policy provides a comprehensive overview of the collection, utilization, and disclosure of your Personal Data by TRAC and its affiliated business groups ("Affiliates"). The primary objectives of this Privacy Policy are as follows:

1. To ensure your understanding of the personal data collected by TRAC, the purposes behind such collection, utilization, and disclosure by TRAC, and the entities collaborated with by TRAC for managing your Personal Data;
2. To delineate the manner in which TRAC leverages the Personal Data shared by you to enhance the customers' experience while utilizing TRAC's services; and
3. To elucidate the rights and choices available to customers regarding their Personal Data collected by TRAC, the processing thereof by TRAC, and the measures adopted by TRAC to safeguard such Personal Data.

TRAC expects this Privacy Policy will help you to understand our commitment to safeguard your Personal Data. Should further clarification be required or if you have additional queries, please do not hesitate to reach out to TRAC via the “Contact Us” section [hyperlinked] included in this Privacy Policy. Remember, should you disagree with the provisions outlined in this Privacy Policy, you retain the choice of whether to utilize TRAC services or not.

C. PRIVACY POLICY SUMMARY
 

This Privacy Policy has been designed to facilitate clear and thorough comprehension of TRAC’s Personal Data protection practices. We encourage you to carefully review the information presented below in order to gain a comprehensive understanding of how TRAC safeguards your Personal Data.

To enhance accessibility, we have outlined the key details in this Summary section.

• Information Collection by TRAC

TRAC gathers information when you:

1. Register on TRAC Platform to access services provided by TRAC

During this process, TRAC will collect Personal Data, including your full name, telephone number, email address, and verify the accuracy of the information you provide.

1. Rent a vehicle from TRAC or utilize TRAC's services available on the platform

For these transactions, TRAC will require more detailed Personal Data, which may include:

1. Name, telephone number, address, and date of birth;
2. Driving License (SIM), Resident Identity Card (KTP), Taxpayer Identification Number (NPWP); and
3. Creditworthiness or other historical information.

We collect information during the reservation and rental processes, allowing you to submit supporting documents to verify the accuracy of your Personal Data.

We gather information regarding your preferences, based on your interactions with us and any special requests you make when utilizing our services. Additionally, data is collected from the devices you use, along with any other information you provide while using the TRAC Platform.

It is essential to communicate that errors or inadequacies in the information you provide to us may hinder our ability to deliver optimal service to you.

• How will information about you be utilized ?

We will utilize your Personal Data for:

• Providing vehicle rental services, including any additional services, and other requested services from TRAC Platform;
• Utilizing the contact information provided to facilitate communication with customers;
• Using "cookies" and other electronic tools to gather statistical data on your TRAC Platform usage. This data serves research purposes and aids in enhancing our services by providing insights on how to improve the TRAC application;
• Analyzing personal information for internal analytical purposes;
• Customizing and delivering TRAC products and services;
• Innovating new features, technologies, and enhancements for TRAC services;
• Using the data for marketing, promotional, advertising campaigns, and other TRAC's programs (if any);
• Using the information as a basis for strategic planning, reporting, business plans, research, surveys, and studies (if needed).

• With whom do we share your information?

In order to provide you with the best possible service, we will disclose your Personal Data to TRAC Affiliates, partners, vendors/suppliers, agents, and collaborators who assist us in serving customers, discount sponsors (if any), licensees, and other relevant entities, within the limits outlined in this Privacy Policy and with your consent as stipulated by applicable laws and regulations.

Additionally, we may share your Personal Data for marketing and advertising purposes with related parties whom have agreement with us, according your consent as required in applicable laws and regulations.

Furthermore, we might share your Personal Data with government agencies, law enforcement, and other relevant parties if mandated by applicable laws and regulations.

• Where is your information processed?

Your Personal Data is securely stored and can be accessed from various locations utilizing cloud services and storage. The server primarily housing this information is situated in the Republic of Indonesia, although storage may also be conducted in other regions.

• How long is your information retained?

We keep your Personal Data for a duration necessary to fulfill the purposes outlined in this Privacy Policy. This retention period is 5 (five) years, unless extended for legal compliance, business decisions based on received data, and dispute resolution.

• How can I assert my rights regarding my information?
   

In accordance with applicable laws and regulations, you hold the rights to access, revise, erase, object to processing, data portability, and avoidance of automated decision-making.

For inquiries concerning your privacy, rights, and their exercise, kindly reach out to us through the “Contact Us” section [hyperlinked] in this Privacy Policy. Should you have any concerns on our handling of your Personal Data, we welcome your collaboration in resolving them.

• Dispute Resolution

In the event that you believe there is a problem or complaint has arisen, we are committed to collaborating with you to address and resolve the issue. Please reach out to us via the "Contact Us" section provided in this Privacy Policy.

• Security
   

Aligned with the objectives outlined in this Privacy Policy, we will diligently implement appropriate measures to safeguard your Personal Data against theft, unauthorized access, disclosure, or modification. Our dedication lies in consistently delivering suitable procedural and electronic security safeguards to uphold the confidentiality of customer information/personal data.

• Notification of Changes

In our ongoing efforts to deliver the best service and ensure legal compliance, periodic revisions to this Privacy Policy may occur. The updated version will be accessible on the TRAC Platform, accompanied by a date stamp to indicate the most recent update. We encourage you to check periodically for any modifications or updates to this Privacy Policy.

We are committed to providing customers with exceptional service while adhering to all relevant laws and regulations, especially those concerning the confidentiality of the Personal Data we collect. This Privacy Policy abides by the laws and regulations of the jurisdiction where TRAC is established.

D. TYPES OF PERSONAL DATA COLLECTED

The personal data we collect aligns with the information outlined on TRAC Platform and type of services that you selected. TRAC, either directly or through our service providers, business partners, discount sponsors, licensees (if any), advertisers, and booking channel providers, gathers personal data provided by you through the application, TRAC Platform, third parties, whether online or offline, in relation to inquiries, orders, rentals, purchases, or any TRAC-related services. This information may also be consolidated with personal details or other data from various online or offline sources. Additionally, we gather personal data from all devices utilized to access TRAC Platform or our authorized service providers.

Provision of personal data is essential for receiving optimal service from us regarding our offered services. Moreover, sharing personal data is imperative regarding the legal or contractual obligations existing between you and us, which can be undertaken voluntarily, depending on the collection and usage purposes of your personal data as delineated in this Privacy Policy. Failure to provide your personal data would result in suboptimal service provision or potential limitations in accessing certain products or services from us. However, unless you do not require our services, the non-disclosure of your personal data will not bear legal ramifications.

Please refrain from sharing information about other parties unless you have been explicitly authorized to do so and have obtained consent to utilize, disclose, and transfer the information in line with our Privacy Policy. By submitting details regarding another party, you confirm that you have the necessary authorization and power of attorney to provide such information. If you or the individual for whom the information is being shared are not residents or citizens of the European Union, consent must be obtained for the collection, usage, and disclosure of information as outlined in our Privacy Policy.

Subject to applicable laws and regulations, we may gather, utilize, and divulge various categories of Personal Data related to you and your engagements with us, which are classified as follows: 

Special Data/Sensitive Data:

In relation to a specific event, it is essential to gather specific Personal Data, such as details concerning your race, religion, or health, which falls under the category of special information or sensitive personal data based on relevant laws and regulations ("Sensitive Personal Data").

Generally, we restrict the instances in which we may gather Sensitive Personal Data. Nevertheless, the collection of Sensitive Personal Data could be necessary to finalize or provide specific services to you or as a response to particular requests from you regarding the services we offer. For instance, data concerning health conditions or membership in trade unions may constitute Sensitive Personal Data in certain jurisdictions. Depending on the stipulations of applicable laws and regulations, we may be unable to process such Sensitive Personal Data without your explicit consent. Data concerning health conditions is classified as Sensitive Personal Data in some regions. Should you request accommodations for disabled users, such as implementing specific control features in a vehicle, Sensitive Personal Data pertaining to health conditions or accidents may arise, and we are obligated to engage with insurance companies (subject to the terms of the contract between you and us) and pertinent claims. Irrespective of the injury sustained, we may need to handle Sensitive Personal Data related to your health condition.

It is crucial to highlight that should you decide to rent a vehicle from us and it necessitates the disclosure of Sensitive Personal Data (in accordance with the aforementioned conditions), then we will exclusively utilize that Sensitive Personal Data for operational purposes to meet your requirements for our services, with your consent in accordance with the prevailing regulations.

E. METHODS AND SOURCES OF COLLECTING PERSONAL DATA

Personal Data is collected in the following ways:

1. using our services, using TRAC Platform; and
2. Engaging with us via email, social media, our contact centre, or any other online or offline channels or mediums.

Additionally, Personal Data may be obtained from our Affiliates, partners, vendors/suppliers, agents, collaborators, discount sponsors (when applicable), licensees, and other relevant entities, strictly aligned with the provisions of this Privacy Policy.

Moreover, in cases where you are authorized to disclose personal data on behalf of another individual or entity to us, you must ensure prior notification and consent from the concerned party regarding the disclosure of their Personal Data, as outlined in this Privacy Policy.

Extensively, we engage in various methods of Personal Data collection which include, but are not limited to, the following approaches:

1. Online or offline channels within our network, stores/kiosks, TRAC Platform, official third-party social media network pages, computer browsers, third-party social media networks, and telematic devices;
2. Phone call to our reservation service, customer service, emergency assistance service, customer contact center;
3. Engagements with licensees (if any) and our Affiliates;
4. Direct collection at rental location;
5. Data obtained via technology in vehicles or equipment within vehicles or through other telematics devices;
6. Membership application as our member/priority member;
7. Data concerning reservations, including cancellations or non-continuations of reservations;
8. Data collected during the vehicle or equipment rental period;
9. Reservations made through us via licensees (if any), travel agents, online, or offline;
10. Information gathered from transactions with us, encompassing options or add-ons availed;
11. Records of costs, incidents, or accidents that may arise during using our services; and
12. Information provided by promotion sponsors and claims service providers (whether our Affiliates or those operated by third parties).

Usage of "Cookies" and Other Electronic Tools:

"Cookies," web server logs, web beacons, pixel tags, or other electronic tools may be used to gather statistical and analytical data on the utilization of TRAC Platform. This information, collected by us (including our collaborating entities, as detailed in our Privacy Policy), is utilized in accordance with this Privacy Policy and within the constraints of relevant laws and regulations. Such use includes but is not limited to operational enhancements, research activities, data analysis, and improving the user experience on TRAC Platform. This may involve facilitating log-in procedures, granting access to specific sections of our applications, platforms, or services, presenting personalized content, and showcasing online advertisements tailored to you or your preferences, as well as compiling anonymous, aggregated data regarding the usage of our applications, platforms, or services.

Should you choose to delete or disable "Cookies," their functionalities may be limited based on the information stored within the "Cookie."

F. PURPOSE OF PROCESSING PERSONAL DATA

Our utilization of your Personal Data is aimed for delivering an optimal level of service to you. This is segmented into specific objectives outlined below:

1. Operation and Service:
    
2. Providing of vehicle rental services along with any complementary services, in line with your preferences as detailed on the TRAC Platform;
    
3. Handling and supporting you through all transactions that related to your service orders;
    
4. Utilizing your information to engage in communication regarding your rental reservations or transaction;
5. Enrolling you in one of our membership schemes;
6. Notifying you of any modifications to the terms or features of our services in which you are involved
    
7. Formalizing a vehicle rental contract/agreement between you and our company, which may include taking pre-contractual measures upon your request for our services;
8. Reaching out to you via phone or SMS on your mobile device in relation to our services;
9. Overseeing, validating, deactivating, or overseeing your account;
10. Facilitating or enabling requisite verifications before service provided, including completion of the Know Your Customer (KYC) process and credit assessments when necessary;
     
11. Managing and addressing inquiries and feedback received from you; and
12. Acting upon your driving behavior (incorporating factors such as geographic location, speed, distance traveled, braking, and damage data) obtained from telematics devices, other tools, vehicle indicators, or based on other criteria that related to your vehicle rental and utilization. It is important to note that such actions may involve the suspension or termination of your renting process with TRAC or its Affiliates.

2) Marketing:

1. Your information will be utilized to deliver marketing information, special offers, and promotions through various channels such as electronic mail (e-mail), telephone, SMS, and other communication applications (including Whatsapp).
    
2. Your data may be used for marketing, promotional, and advertising purposes, in addition to any other programs offered by TRAC.
    
3. You may receive marketing and promotional materials from TRAC and its Affiliates.
    
4. Surveys may be sent to your electronic mail (e-mail) and other communication applications (including WhatsApp).
5. You will be given the opportunity to engage in the interactive features of our websites and applications, should you opt to do so.

Please be advised that should you provide consent for receiving marketing communications, we will process your Personal Data for this specific purpose with your approval. Nevertheless, in compliance with applicable laws and regulations, in cases where permitted, we may utilize your Personal Data for marketing communications without explicitly seeking your consent. In such instances, processing of your Personal Data for marketing purposes will be conducted in our legitimate interests, encompassing the promotion of products and services, as well as the dissemination of special offers and promotions that may be of interest to you.

We would like to inform you that by reaching out to us through the  "Contact Us" [hyperlinked] section, you have the option to:

• Opt-out of receiving marketing-related communications at any point; and
• Request us to refrain from utilizing Personal Data outlined in this Privacy Policy for transmitting special offers and promotions.

Please be aware that the process to fulfill the aforementioned requests may take some time to ensure compliance with relevant laws and regulations.

3) Regarding Other Objectives:

1. To ensure compliance with pertinent laws and regulations, promptly address summons or requests for information from law enforcement agencies, court orders, or other legal proceedings;
    
2. Supervise and recording calls for enhancing quality, training, legal adherence, analytics, and other associated objectives to enhanced our service delivery;
3. Continuously maintain, enhance, test, refine, and personalize TRAC Platform to align with your preferences and requirements;
4. Safeguarding the interests, rights, safety, and assets of ourselves and other involved parties;
5. Enforcing terms of service in our applications, platforms, or services, encompassing conditions relevant to vehicle rentals or our complimentary services;
6. Fulfilling your requested services, including other activities that linked to those services such as invoicing and vehicle withdrawal;
7. Offering you exclusive promotions or special deals that may be of interest to you (if permissible);
8. Part of a business transaction that involves the purchase, sale, or transfer of all or part of our assets in adherence to applicable laws and contractual obligations;
9. Ensuring a proper operation of our systems;
10. Enhancing TRAC Platform and optimizing the presentation of TRAC Platform content for you and your devices;
11. Addressing your queries, requests, or feedback and applying our terms, conditions, and policies;
12. Upholding security of TRAC Platform;
13. Aggregating your data into anonymized statistical data for statistical analysis to enhance our understanding of customer profiles and improve our services;
14. Providing help to rectify technical challenges or operational issues with TRAC Platform;
15. Mitigating, identifying, and investigating any unauthorized, illegal, prohibited, or fraudulent activities; and
16. For other specified purposes, as mandated by applicable laws and regulations, we will request your consent accordingly.

In the context of the aforementioned objectives, you retain the right to withdraw your consent at any moment by reaching out to us as detailed in the "Contact Us" section of this Privacy Policy.

G. DISCLOSURE OF CUSTOMER DATA

By giving your consent to this Privacy Policy, we will disclose your Personal Data to third parties who collaborate with us or are part of our network to fulfill the objectives outlined in this Privacy Policy and deliver the best possible service to you, including:

1) Designated Third Party

We may share your Personal Data and other relevant information with service providers, business partners, discount sponsors, designated parties, advertisers, and other entities that offer services to us or to you, carry out tasks on our behalf, or engage in commercial partnerships with us. We may provide aggregated or anonymized data regarding TRAC Platform users to third parties, such as rental information. This data is useful in delivering vehicle rental services to you, including but not limited to verifying your identity before we provide our services and enhancing the functionality of the TRAC Platform. Additionally, we may disclose such information when necessary to facilitate reservations or rentals, address service-related issues, or conduct other activities associated with the services we provide to you.

Furthermore, we may disclose information to third parties for the following reasons: (i) safeguarding the concerns, rights, and safety of our fleet of Vehicles; (ii) enforcing the terms of service on the TRAC Platform or the terms and conditions, and rental agreement between you and TRAC, which included billing and withdrawal; (iii) offering you promotions that might interest you; (iv) as part of a business transaction in the event that all or a portion of our assets are acquired, sold, or transferred in accordance with applicable laws and regulations; and (v) ensuring the proper functioning of our systems.

2) Affiliates

In order to assist our Affiliates in delivering relevant services to you, we may share your Personal Data with our Affiliates to enhance our vehicle rental services to you, as well as for promotion and marketing initiatives offered by TRAC and its Affiliates.

3) Internal Employees/Individuals

Our dedicated employees who responsible for providing services to you will have access to your Personal Data as part of their responsibilities which ensuring its compliance with regulations and safeguarding against any infractions. This access helps us maintain our commitment to deliver a comprehensive and optimal service to you consistently.

4) Government Institutions/Law Enforcement Officials

We may divulge your Personal Data to Government Agencies and Law Enforcement Officials when deemed essential for legal compliance, responding to information requests, court orders, law enforcement mandates, or other lawful proceedings. Moreover, we may disclose your Personal Data to our legal counsel to uphold, exercise, or defend our legal rights, or to our other professional advisors, or as permissible or obligatory under the law. Additionally, we retain the right to share your Personal Data to avert threats to the well-being, health, or safety of individuals or corporate entities. Your Personal Data will also be disclosed as necessary to investigate suspected illicit activities, encompassing fraud, breaches of intellectual property rights, or violations of privacy.

You may direct us at any time to refrain from sharing your Personal Data described in this Privacy Policy with third parties by contacting us through the "Contact Us" section as detailed in this Privacy Policy. Furthermore, we wish to advise you that (i) the selection process regarding your application from us complies with the relevant laws and regulations, requiring some time; and (ii) subsequent to our processing, your Personal Data and other information may still be shared with our Affiliates and designated service providers.

In addition to the aforementioned disclosures, your Personal Data may also be disclosed under the following circumstances:

1) Social Media

When utilizing TRAC Platform or our social media channels, please be mindful that any Personal Data voluntarily disclosed by you or other individuals through these features may become accessible to the public or designated users. Moreover, if you opt to grant access to a designated party or individual, please note that all information shared can be viewed by that party or individual. It is essential to note that we hold no liability for the information you choose to disclose publicly, and the utilization of such information by us or other parties is not governed by this Privacy Policy.

2) Third Party Websites/Links

In instances where you provide your Personal Data on other Third Party Websites/Links, either directly or indirectly linked to the services we offer, we are not responsible for the information you give on their respective websites or links, as we lack direct control over those third-party sites. We suggest that you review the privacy policies of each website before giving your information to the pertinent third party.

Please be aware that when Personal Data does not necessitate association with you, we will attempt to dissociate your Personal Data appropriately. It is imperative to emphasize that we do not engage in sale of your Personal Data. Additionally, we would like to notify you that in cases where the disclosure of your Personal Data to third parties is essential in accordance with pertinent laws and regulations, we obligate these third parties through written agreements to safeguard your Personal Data shared with them.

H. TRANSFER OF INFORMATION OVERSEAS

Certain uses and disclosures outlined in this Privacy Policy may necessitate the transference and processing of your Personal Data across various countries globally. These countries may exhibit varying levels of personal data safeguarding compared to the Republic of Indonesia or your domicile.

The transfer of your Personal Data could arise under the following circumstances:

1) When utilizing our TRAC Platform beyond the borders of the Republic of Indonesia
 

Should you utilize the TRAC Platform in a foreign nation where access is facilitated, we keep the ability to transfer your Personal Data from the Republic of Indonesia to the relevant destination country where platform access is granted, allowing for an optimal user experience.

2) When your Personal Data/Information is saved and processing outside the Republic of Indonesia
 

Subsequently, your Personal Information may be held or processed outside Republic of Indonesia by our external representatives or personnel, or by third-party service providers, vendors, suppliers, partners, contractors, or our Affiliates.

In both scenarios, we enforce a formal written agreement (contract) with the recipients/processors of personal data situated outside Republic of Indonesia to govern the protection of your Personal Data beyond the nation's borders. Should you wish to obtain a copy of these standard contractual clauses, please reach out to us via the contact details specified in the “Contact Us” section of this Privacy Policy.

I. GENERAL RIGHTS OF DATA SUBJECTS

In compliance with relevant laws and regulations of Republic of Indonesia, individuals may possess certain rights concerning the management and processing of Personal Data acquired by us. These rights include:

1) Right to Information Processing

You are entitled to receive information related to the transparency of identity, the legal grounds for processing, the purposes of data collection and utilization, and our accountability, which we gave and informed in this Privacy Policy.

2) Right to Amendment/Rectification

You possess the authority to rectify, amend, or update any inaccuracies and/or deficiencies in Personal Data that you have given to us, which you believe are incorrect and do not align with actual facts.

3) Right of Access to Your Personal Data/Information

You have the right to be informed about the status of the processing of your Personal Data. In the event of our processing of your Personal Data, you can view the Personal Data related to you, as well as specific details regarding our processing and utilization of such data, including its sharing practices.

Subject to compliance with applicable laws and regulations, we reserve the right to charge a reasonable administrative fee for your access rights. Moreover, under exceptional circumstances, we retain the prerogative to deny you access to your Personal Data that is under our custody, providing an explanation as mandated by the prevailing laws and regulations where feasible.

Exceptions may arise, in line with the permissions granted under relevant laws and regulations, including:

• Law enforcement agencies, governmental institution, or investigative  authorities dissent to our adherence to your request;
• Situations wherein the information, based on our reasonable discretion and/or judgment, could impact the life or safety of any individual; and/or
• Data is collected in connection with your inquiry into breaches of agreements, suspected instances of fraudulent activities, and/or violations of the law.

4) Termination of Processing, Deletion, and Destroying of Personal Data

If you do not have any outstanding arrears, violations, or other obligations to our company and do not currently utilize our services, you are entitled to request the deletion, to end of processing activities, and/or destroying of Personal Data we hold on record for you. This request may be granted as long as the following conditions:

meet the following conditions:

a) If you no longer intend to use our services and hence do not require the retention of your Personal Data by us;

b) In cases where we currently process your Personal Data with your consent, and you wish to revoke this consent, thereby negating the legal basis for further processing of your Personal Data;

c) If we are processing your Personal Data based on our legitimate interests, but you object to such processing and provide detailed grounds for your objection, allowing us to evaluate whether there is a main interest in retaining your Personal Data;

d) If you refuse receiving promotions, special offers, marketing material, and/or sweepstakes utilizing your Personal Data; and

e) In situations where you suspect that your Personal Data is being processed unlawfully by us.

To facilitate the termination of processing, deletion, and/or destroying your Personal Data, a comprehensive explanation of the rationale behind asserting any of these rights is necessary. This will enable us to ascertain whether you have a valid basis to request the termination of processing, deletion, and/or destroying your Personal Data. It is essential to note that we may uphold the retention of your Personal Data if there exists a lawful reason as per relevant statutes and regulations. Kindly be advised that upon completion of the processing, deletion, and/or destroying your Personal Data, we will no longer be able to provide our services to you. 

Should you request the termination of processing, deletion, and/or destroying your published Personal Data with valid justifications, we will make reasonable efforts to notify third parties displaying or linking to your Personal Data to effect its deletion as well.

5) Right to Withdraw Consent

If you have valid reasons based on applicable laws and regulations, you may request withdrawal of your consent regarding the processing of your Personal Data. However, please ensure that there are no outstanding arrears, violations, and/or obligations to us, and that you are not currently using our services.

6) Right to Give Feedback and Complaints

Should you have any issues, input, or complaints concerning the utilization and/or disclosure of your Personal Data, you can give us your feedback or complaints. We welcome and value your input and suggestions.

7) Right of Restriction of Processing to Storage Only

You have the right to request termination of processing your Personal Data that is under our protection, solely for storage purposes under specific circumstances. It is important to note that should we stop processing your Personal Data, we reserve the right to resume its usage if there are valid reasons in compliance with prevailing laws and regulations.

The conditions under which you can request the suspension of processing your Personal Data solely for storage purposes, are followed:

a)  If you believe that your Personal Data is inaccurate, requiring verification before further processing;

b)  Should you wish to retain your Personal Data despite our obligation to delete it for regulatory compliance;

1. In cases where there is no longer a necessity to retain your Personal Data as outlined in this Privacy Policy, yet you require its retention for potential legal proceedings; and
2. If you oppose our processing of your Personal Data, notwithstanding compliance with our Privacy Policy and relevant laws and regulations, while preferring terminate the process. Under such circumstances, we will assess if there is a legitimate interest on our part to retain your Personal Data.

8) Right to Portability

You possess the entitlement to obtain a portion of your Personal Data in a structured, commonly used, and machine-readable format, and the right to transfer of your Personal Data to a designated party.

It is mandatory for us to convey that the aforementioned subset consist of data given by you with your explicit consent. Should you wish for us to transmit your Personal Data to a designated party, it is imperative that you specify the identity of said party and acknowledge that such transfer is based on our technical and operational capacities. Please be advised that we bear no liability for the security of your Personal Data or its processing subsequent to being received by the designated party. Furthermore, we reserve the right to withhold certain Personal Data if the disclosure thereof would infringe upon the rights of third parties.

Protocol for Exercising Your Rights:

Kindly note that the assertion of your rights articulated in this Privacy Policy represent a formal request from you to us. We respectfully urge you to give comprehensive details relate to the rationale behind your assertion of rights so that we may assess the validity of your claim.

In processing your requests, we request that you give essential reasons and identifying particulars relate to your request for the purpose of verifying your identity or facilitating the intended processing as delineated in this Privacy Policy. This information may include filling in the form of your Full Name, Residential Address, Email Address, Telephone Number, a Copy of Your Identity Document, and your reason for exercising your rights.

All requests should be directed to the Email address detailed in the "Contact Us" segment of this Privacy Policy. Kindly be advised that submissions made through channels other than those specified in this Privacy Policy, or those devoid of the requisite information as stipulated herein, may necessitate a longer processing time, risk non-acceptance by us, and potential delays in response within the stipulated timeframes.

J. COOKIE

Cookies are text files that contain information downloaded to your device upon accessing the TRAC Platform. It is imperative to notify you that you have the option to configure your device settings to either disable cookies or receive notifications when cookies are transmitted. Certain browser settings provide guidelines on managing notifications for cookies, disabling cookies, or turning off geolocation data.

Moreover, it is essential to acknowledge that TRAC collaborates with third parties to support in developing engaging advertisements for you based on your TRAC Platform usage. These third-party companies may employ cookies to track your preferences and user behavior to deliver personalized advertising across various services and products. Each company or website employing cookies operates under a privacy policy governing the use of your personal data.

Should you opt to disable cookies or decline cookie placement requests, certain features on the TRAC Platform or other websites may not function correctly. Likewise, the advertisements you encounter on our website or elsewhere may not align with your preferences. Please be aware that we may not acknowledge "do not track" signals or similar mechanisms indicating a request to disable online tracking on the TRAC Platform.

While opting out of targeted advertising, general online advertisements will still be displayed to you. Your information and interactions with us may be captured and utilized for delivering targeted advertising on our platform.

Besides utilizing your device's provided functionalities, you can prevent information collection by:

1) Uninstalling the App

To halt information gathering by the app, simply uninstall it using the standard uninstallation process through your mobile device settings or on the mobile application network from which you downloaded the application.

2) Opting Out of Interest-Based Ads

Contact us via the "Contact Us" section in this Privacy Policy to learn how to opt out of information usage for personalized advertising by third-party advertisers or networks. Please note that opting out of targeted ads restricts customized advertisements but does not eliminate all ads.

3) For Apple Users:

To adjust your settings, navigate to Settings > Privacy > Advertising. For further details, please refer to Apple's official website at www.support.apple.com.

4) For Users of Other Major Mobile Device Platforms:

Access the settings on your mobile device and choose the “Ads” section.

5) Opting Out of Location Data Collection:

Access your mobile device settings, then select “Settings” to opt out of location data collection.

K. MARKETING AND PROMOTIONAL MATERIALS :

We, along with our Affiliates, vendors, agents, and related third parties as outlined in this Privacy Policy, may send you marketing materials, advertising, and promotional communications via various channels such as push-notifications, in-app messages, postal mail, phone calls, SMS, chat platforms, social media, and email ("Marketing") upon your subscription to our mailing list or agreement to receive such materials. You can opt out of receiving these Marketing communications at any time by choosing the “Unsubscribe” option in the messages we send or by contacting us through the methods provided in the "Contact Us" section of this Privacy Policy.

L. RETENTION

We will retain your Personal Data for the duration necessary to fulfill the purposes outlined in this Privacy Policy or as mandated by applicable laws and regulations. Typically, we will retain your personal information for a period of 7 (seven) years, with possible extensions for legal compliance, data-driven business decisions, and dispute resolution (if any).

M. ACCURACY

Your assistance in maintaining current, valid, complete, and accurate Personal Data is vital. Kindly notify us of any changes to your Personal Data by following the instructions in the "Contact Us" section of this Privacy Policy. Furthermore, you have the option to update your Personal Data at any time by making changes to your account.

We may also request updates to your Personal Data periodically. As previously outlined, scenarios may arise where the disclosure of rental transaction information between you and us to Government Agencies or other Law Enforcement Officials is mandated by relevant laws and regulations. Hence, it is crucial to ensure that the Personal Data encompassed in rental transactions between you and us remains current, comprehensive, and precise.

N. SECURITY PROTECTION

Safeguarding the confidentiality of your Personal Data is our foremost priority. We will exert our utmost efforts to protect and fortify your Personal Data against unauthorized access, collection, use, or disclosure, as well as from illicit processing, accidental loss, destruction, damage, or similar risks. While we are committed to taking the security of your Personal Data seriously, it is essential to acknowledge that transmitting information via the internet is not entirely risk-free. We will persist in our best efforts to shield your Personal Data; however, we cannot warrant the security of your Personal Data transmitted through the website, mobile application, or any other means, hence assuming associated risks lies with you.

Furthermore, we cannot assure the completeness and accuracy of your Personal Data on the internet, nor can we guarantee your personal data from interception, access, disclosure, alteration, or destruction by unauthorized parties, due to external factors beyond our control. Consequently, you are accountable for upholding the confidentiality of your Account details and Personal Data. You are obliged not to divulge your Account details (including the password, One-Time Password ("OTP")) to anyone and must consistently uphold and take responsibility for securing the device you utilize.

O. WEBSITES AND OTHER SERVICES

Occasionally, where necessary, we may give you links to other websites or applications for your convenience and to enhance information comprehensiveness. Should you choose to visit, follow, or acquire services from or through TRAC Platform, please acknowledge that TRAC Platform maintains its own Privacy Policy, and we disclaim any accountability for this Privacy Policy. Your access to such websites or applications is at your own discretion, and we bear no responsibility for said websites or applications.

In our effort to safeguard your Personal Data on TRAC Platform, we are unable to regulate or responsible for the practices of external websites or applications to which we may provide links, or for the handling of any Personal Data you choose to disclose to them. It is essential to underline that this Privacy Policy excludes other sites, and we highly advise that you familiarize yourself with the individual privacy policy of every website or application.

P. MINORS

The TRAC Platform is designed for individuals aged 16 (sixteen) years and older. Due to our inability to determine the age of website or application users, if minors have provided Personal Data without parental or legal guardian consent as required by laws, please refer to the designated procedures outlined in the "Contact Us" section of our Privacy Policy to request the deletion of relevant Personal Data and to unsubscribe minors. In the event that Personal Data has been acquired from individuals under the age of 16 (sixteen) years without proper consent, we will promptly delete the data, deactivate their account, and nullify its validity.

Q. UPDATE THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy periodically and the updated versions will be published on the TRAC Platform. The date of the latest update will be clearly indicated for your reference. It is advisable to periodically review this Privacy Policy for any revisions or updates. Should there be any substantial alterations made to this Privacy Policy, notice will be provided via email. Please note that in accordance with applicable laws and regulations, the Indonesian version of this Privacy Policy supersedes all other versions or translations.

R. CONTACT US

For any comments, inquiries, complaints, or to assert your rights as detailed in this Privacy Policy, kindly contact TRAC in writing at the following address:

TRAC DPO,

GRHA SERA, Jalan Mitra Sunter Boulevard Kav. 90/C2,

Sunter Jaya, Kota Administrasi Jakarta Utara,

DKI Jakarta, Republik Indonesia 14350

For inquiries, comments, questions, or complaints regarding TRAC services, please reach out to us at:

Call Center: 1500-009

Customer Assistance Center: 08999500009

Email Customer Care: trac.astrarentcar@ai.astra.co.id 

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