Privacy Policy

We may need to gather your personal data from time to time in order to offer you the goods or services you require, which may include:

Telekomunikasi Indonesia International (Hongkong) Limited and all of its affiliates (from now on referred to as “Telin Hong Kong,” “us,” “we”, or “our”) are subject to the requirements of the Personal Data (Privacy) Ordinance (PDPO), Chapter 486 of the Laws of Hong Kong. Our employees adhere to the strictest security and confidentiality standards for all personal information and data transmitted through our products and services to ensure that all requirements are followed. This Privacy Policy (“Policies”) describes how Telin Hong Kong collects, uses, and shares information about you and gives you the choice of how your data is collected, used, shared, and transferred. 

Information we collected and why we collect it

1. Personal Data; Personal data we collected includes:
   1. Your name
   2. Your billing address
   3. Your account information, including account numbers, service numbers or user account
   4. Your identity card numbers (HKID/ Passport/ other Identity documents)
   5. Your payment details, including banking information or credit card
   6. Contact information, such as name, phone number, fax number, or email address
   7. Device address and unique device identifier (IMEI/android ID/IDFA/OPENUDID/GUID, SIM IMSI Information).

You are not compelled to provide us with your personal data; however, if you refuse to do so, we may be unable to provide you with the required goods and services.

2. Device and Information

We automatically gather device information when installing, accessing, and using our services. Your device model, operating system, and IP address are all included. This devices’ information is used to enhance the quality of our application. 

How we use

Depending on the circumstances, your personal data may be used for one or more of the following purposes:

• To verify your identity; 
• To process your application for any service; 
• To process your orders of goods or services;
• To communicate with you; 
• To facilitate the daily operation of the services provided to you; 
• To conduct customer due diligence as required by law and regulations; 
• To provide you with marketing and promotional materials for your enjoyment of benefits;
• To facilitate Telin Hong Kong’s use of your personal data for purposes relating to the provision of services offered by Telin Hong Kong  and/or our merchants, and marketing services, special events, and/or promotions of Telin Hong Kong and/or our merchants;
• To handle and investigate complaints and other inquiries; 
• To facilitate Telin Hong Kong’s use of your personal data for purposes relating to the provision of services offered by Telin Hong Kong and/or our partners, and marketing services, special events, and/or promotions of Telin Hong Kong and/or our partners;
• Loyalty program administration, operation, and management;
• Developing and upgrading services and products to meet your specific requirements;
• Billing
• Processing payment instructions
• Daily administration and management of our business
• Credit checking and debt recovery (including the employment of debt recovery agents and civil processes).
• Obtaining legal counsel and making legal claims or defenses, as well as participating in legal processes;
• Fraud and crime prevention and investigation;
• Disclosure as permitted or required by any jurisdiction’s laws, regulations, and court orders, and/or as required by any government, regulatory, or law enforcement authority;
• Any such incidental or related reasons connected to the aforementioned, as well as any other purposes you may agree to from time to time.

How we collect information

We collect data when you provide information to us or through mobile applications or web technologies

Android System

SDK Name	Description and Official Website
Flutter 2.10.5	Mobile Application Framework. Flutter is an open-source UI software development kit created by Google. A popular, multi-platform UI toolkit that’s powered by the Dart platform, and that provides tooling and UI libraries to build UI experiences that run on iOS, Android, macOS, Windows, Linux, and the web. https://flutter.dev/
Dart 2.16.2	Programming Language. Dart is a client-optimized language for developing fast apps on any platform. Its goal is to offer the most productive programming language for multi-platform development. The Dart language is type safe and offers sound null safety. https://dart.dev/
Android SDK (21-30)	Mobile OS Software Development Kit (SDK) provided by Google Developers. https://developer.android.com/studio
Kotlin SDK 7	Programming Language. Kotlin is a mature programming language that is concise, safe, interoperable with multiple languages, and provides many ways to reuse code between multiple platforms for productive programming. https://kotlinlang.org/

Disclosure or Transfer of Personal Data

Subject to the conditions of this section, we commit to take all reasonable means to keep all of your personal data confidential and/or unpublished. We will only share and/or transfer your personal information with our people and staff to provide you with services. However, under the following circumstances, we may disclose and/or transmit such information to third parties:

• Where the information is disclosed and transferred to any third party who we have duly authorized to use such information under a duty of confidentiality; 
• Where the information is disclosed and/or transferred to any Telin Hong Kong agents, affiliates, or associates who we have duly authorized to use such information;
• Where Telin Hong Kong thinks it essential to do so to comply with applicable laws and regulations, including without limitation compliance with judicial action, court order, or legal process served on Telin Hong Kong and/or our merchants;
• Where Telin Hong Kong needs to protect and defend our rights and property;
• Telin Hong Kong may transfer, keep, and analyze personal data gathered in any country where Telin operates. Under the situations described above, you are deemed to have agreed, consented, and allowed us to disclose and/or transfer your personal information.

We may share your personal information with the following parties, or any of them, for the purposes stated above:

• any of the Telin Hong Kong’s agents, contractors, subcontractors, or associates (including their employees, officers, agents, contractors, service providers, and professional advisers);
• any third-party service providers (including their employees and officers) who provide services to us or any affiliate of our parent company, PT Telkom Indonesia (Persero) Tbk (Telkom), in connection with the operation or maintenance of our business;
• any Authorities;
• any persons bound by a duty of confidentiality to us or a  PT Telkom Indonesia (Persero) Tbk. (Telkom) subsidiary who have agreed to keep such information private;
• any affiliate of  PT Telkom Indonesia (Persero) Tbk. (Telkom);
• PT Telkom Indonesia (Persero) Tbk. (Telkom) co-branding partners or any PT Telkom Indonesia (Persero) Tbk. (Telkom) (the names of such co-branding partners will be provided throughout the application process for the relevant products and services, as the case may be); and
• charitable or non-profit making organizations.
• Telecommunications network operators;
• Third Party reward and loyalty programs providers;
• Financial institutions, charge or credit card issuers, credit providers, credit information or reference bureaus, or collection agencies, as well as security agencies,
• Any actual or projected assignment of all or a portion of the Company’s business and/or assets.

Disclosure or Transfer of Data

You may access your personal information that we have collected and correct factual errors in your personal information by sending us a request that credibly shows the error. You also have the right to ascertain our policies and practices concerning personal data and be informed of the kind of personal data held by us.

We will take reasonable steps to verify your identity before granting access or making corrections to protect your privacy and security. We reserve the right to charge you a reasonable fee for complying with any request for access to your data.

Security

We will always strive to ensure that your personal data will be protected against unauthorized access, processing, erasure, or other use. We have implemented appropriate electronic, physical, and managerial measures to safeguard, protect and secure your personal information.

All personal information you provide is only accessible by the authorized personnel of Telin Hong Kong or our authorized third parties. Such personnel shall be instructed to observe the terms of this Policy when accessing such data. You may rest assured that Telin Hong Kong will only keep your personal information for as long as is necessary to fulfill the purpose for which it is collected. To support electronic transactions, we may engage third-party payment gateway service providers. 

The online browser and third-party payment gateway transmit sensitive information you provide for completing any electronic transactions, utilizing secure Socket Layer Technology (SSL). We also use HTTPS (“HyperText Transfer Protocol Secure”) for data transfers through MyGraPARI App, CAPTCHAs (“Completely Automated Public Turing Test to Tell Computers and Humans Apart”) on MyGraPARI App, regular penetration checks, encryption and masking methods for images to ensure sensitive data is well protected, and One-Time Password (OTP) mechanism for personal verification. You must protect your OTP by keeping them hidden and private. Never, ever, ever share the password. If you believe your password has been shared with another person, stolen, or used in an unauthorized transaction, you must notify us immediately.

There is no such thing as 100 percent secure Internet transmission or computer storage. As a result, while we make every effort to safeguard your personal information from unauthorized access, we cannot guarantee its complete security.

Retention of Personal Data

Your personal information will only be stored on servers in Hong Kong if you use the MyGraPARI mobile application. Your personal data is kept as long as the application services are still available, which is determined on an annual basis. If your personal data was collected through a single MyGraPARI event or special event (such as a lucky draw registration, gift redemption, event participation, etc. ), it will be stored only until the end of the event or its data retention period, as determined by the terms and conditions of the related event.

Use of Personal Data in Direct Marketing

We intend to use your personal data, including but not limited to the personal data described in the previous section, to deliver to you information about any goods and services, loyalty programs, activities (including joint collaboration with third parties), newsletters, contests, lucky draws, and other activities of us and our business partners, subject to your consent and in strict accordance with the provisions of the PDPO. Mobile voice, SMS, and data communications, IDD/roaming, Internet connectivity, mobile applications, entertainment and data communications on the Internet, and other value-added services, may all be included in the said information. You may get said information via mail, phone, email, fax, or other means. 

We may not use your personal data for direct marketing purposes unless you have given us your permission or indicated that you have no objection. You may opt out of receiving direct marketing materials from us at any time by writing to us in the manner described in the contact us section. Please provide your personal information and contact information in any such request for identification purposes.

Use of Cookies and location data

We may use cookie files to record and monitor information about you and your preferences if you visit any of our websites. A cookie is a little text file that our website saves on your computer’s hard drive. We can better serve you and/or keep your information across numerous pages inside or across one or more sessions by using cookies. Most web browsers allow cookies by default, but if you prefer, you can change your phone settings to prevent them from being accepted in the future. Cookies save information about your preferences and personal information. If you are trying to connect with our customer service, for example, the site may establish a cookie containing the information you provided. It might also just keep track of which pages on the site you viewed so that the site can tailor the experience for you the next time you return. A cookie can only store the information you provide or the choices you make while visiting a website. For example, unless you choose to type your email address, the site will not be able to determine it. Allowing a website to create a cookie does not grant that site or any other site access to the rest of your device, and the cookie can only be viewed by the site that produced it.

Data Sharing and Disclosure

To achieve the aforementioned goal, we may use third-party Software Development Kits (SDKs) to assure the operational reliability of our services or to integrate relevant functionality. For more information about the specific circumstances of collecting your personal data, you can check the third-party Software Development Kits (SDKs) privacy policy website, which is provided by Telin Hong Kong. If a third party does not provide a specific privacy policy for its SDKs, we may give a link to the third party’s official website to assist you in understanding its specific information.

Data Access or Correction

You have the right to view and update your personal data that we hold. Please write to us at the address below if you would like a copy of any of your personal data or if you believe that any of your Personal Data that we collect and retain is erroneous.

Data Privacy Officer
Telekomunikasi Indonesia International (Hongkong) Limited
Suite 810 & 905, Ocean Centre, 5 Canton Road
Tsim Sha Tsui, Kowloon, Hong Kong
Hotline: 171161 (Toll Free) / +852 52484000 (WhatsApp Customer Service) 

You may send us a request for access to or correction of your personal data, as well as information about our policies and practices and the types of personal data we hold, to the following address. We have the right to charge a reasonable fee for the processing of any data access request under the PDPO

You can query about your personal information by logging into the MyGraPARI app, and the procedure of inquiry is as follows:

Service > Customer Service > Contact Customer Service

To ensure the security of your information, we may ask you to authenticate yourself before processing your request.

Changes in this Policy

We reserve the right to update, revise, alter, or amend this Policy in the following ways as needed, and it is strongly advised that you review it periodically. We shall post the most recent version of this policy on this website, and/or other locations we consider suitable if we update, revise, change, or amend it.

Updated on June, 1^st 2022 in Hong Kong.