Privacy Policy

Waroeng Spesial Sambal (Waroeng SS), we are committed to protecting your privacy. This Mobile Privacy Policy (this "Policy") describes our practices in connection with information privacy on Personal Data we process through your individual use of the following services, products, and related mobile applications (collectively, the "Products"):

• SipedaSS Application

Before you use our Products, please carefully read through this Policy and understand our purposes and practices of collection, processing of your Personal Data, including how we use, store, share and transfer Personal Data. In the Policy you will also find ways to execute your rights of access, update, delete or protect your Personal Data.

When you accept this Policy when you register with your Personal Data, or if you start to use our Products and does not expressly object to the contents of this Policy, we will consider that you fully understand and agree with this Policy. If you have any question regarding this Policy, please do not hesitate to contact us via: luhurcebolanugrah@gmail.com

Definitions

In this Policy, Personal Data means information generated, collected, recorded and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information and other information we have access to about that individual.

Personal Sensitive Data includes personal biometric information, face data, and precise location information. When we collect Personal Sensitive Data from you, we will generate an explicit notification for your consent before we collection personal sensitive data about you.

*What Personal Data Do We Collect*

In order to provide our Products to you, we will ask you to provide necessary Personal Data that is required to provide those Products. If you do not provide your Personal Data, we may not be able to provide you with the Products.

*1. Information You Voluntarily Provide Us*

Presensi (Attendance Tracking): When you do an "Presensi", we may collect your workshift, check-in and check-out time, geo-location information and login credentials. In order to do an "Presensi", geo-location is required, such as latitude and longitude position. We will collect and process your location information to enable certain functions, such as sending attendance data.

If you authorize "Presensi" with a face detection (Optional), we will obtain your face picture using camera which may be bound with your account for us to manually validate that face matches with the your face data in our server. We will ensure compliance with applicable data protection laws and regulations, as well as agreements, policies or documentations agreed with such third party regarding sharing personal information, in processing your Personal Data.

Based on your consent, when you enable the geo-fence feature on the Products, your location information will be generated and shared with Google Map services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details: https://privacy.google.com/businesses/gdprservices/.

Or for the following specific purposes mentioned below:

• Login credential: Login credential username for login purposes.

• Geo-Location: We will collect and process your latitude and longitude location information to send your attendance data.

• User's Image (Optional): SipedaSS will collects & stores your face image data to enable Presensi / Attendance features, only if you not disable it on settings menu.

*2. Information We Collect Automatically*

• Device Information: When you interact with our Product, we automatically collect device information, such as the operating system type and version, application version number, unique identifiers, device type and model.

• Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.

• Log Information: When you use our app, the system and exception log may be uploaded. Please note that one cannot identify a specific individual by using Device Information or Log Information alone. However, if these types of non-personal information, combined with other information , may be used to identify a specific individual, such non-personal information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will anonymize and desensitize such non-personal information.

*Purposes and Legal Basis for Processing Personal Data*

The purpose for which we may process information about you are as follows:

• Provide You Services: We process your account and face data, device information, usage data, and location information to provide you with our Products and Services that you have requested. The legal basis for this processing is to perform our contract with you according to our Terms of Use.,

• Improve Our Services: We process your device information, usage data to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

• Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

• Personalization: We may process your account data, usage data, device information to personalize product design and to provide you with services tailored for you. The legal basis for this processing is your consent.

• Legal Compliance: We may process your Personal and Face Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

If there is any change in the purposes for processing your personal and face data, we will inform such change to you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Persona & Face Data.

*Who do We Share Personal Data with?*

At Waroeng SS, we do not share your Personal Data in any ways.

*• Withdrawal of consent*: We will exercise your privacy right to withdraw consent through the following approaches:

1) For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including location, camera, and other related functions;

When you withdraw your consent or authorization, we may not be able to continue to provide you with the products or services correspondingly. However, your withdrawal of your consent or authorization will not affect the processing of personal information based on your consent before the withdrawal.

About Delete of the Account: You can contact us through the email (luhurcebolanugrah@gmail.com) for delete account request.

*Security Measures*

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. Waroeng SS provides various security strategies to effectively ensure data security of user and device. As for device access, Waroeng SS proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization. As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported. As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. 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), you could immediately notify us of the problem by emailing luhurcebolanugrah@gmail.com.

*Data Retention*

We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.

*Children’s Privacy*

Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from anyone under the age of thirteen (13) unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from anyone under the age of thirteen (13) without permission from that child’s parent or legal guardian, we will take steps to remove that information.

*Changes to this Policy Policy*

We may update this Privacy Policy to reflect changes to our information practices, at least on an annual basis. If we make any material changes we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

*Contact Us*

If you have any questions about our practices or this Privacy Policy, please contact us as follows: Email: luhurcebolanugrah@gmail.com.