Privacy Policy :: Smart Presence

DEFINITIONS

Unless otherwise defined in this Privacy Policy, all capitalized terms used in this Privacy Policy have the following meanings:

• " Affiliate" is any company or other entity, directly or indirectly, controlling, controlled by, or under common control with Us.
• " You" may refer to you as the party accessing Our Service.
• " Personal Data" is any data that identifies or can be used to identify, contact, or locate you, alone or in combination with other information, directly or indirectly, in Our electronic and/or non-electronic systems including but not limited to your name, your short name, your nickname, your residential address or citizenship status, gender, occupation, telephone number, International Mobile Equipment Identity (IMEI), home address, Global Positioning System (GPS), email address, your image, government-issued identification number, date of birth, marital status, religion, bank details, your facial structure, information about you that you have provided to Us in registration forms, application forms or other similar forms and/or information about you that has been or may be collected, stored, used and processed by Us from time to time.
• " We" is CV. CyberNet IT Solutions, as the organizer of a private scope electronic system, which is the owner or responsible for the Service.
• " Our Contact" is the means you can use to contact Us for the purposes of implementing this Privacy Policy.
• " Competent Authority" is an institution or agency that has authority under applicable laws and regulations, including but not limited to; ministries, non-departmental agencies, courts, and/or law enforcement officials.
• " Processing" or " Process", depending on the context and sequence of words used in a sentence, is the activity of acquisition and collection, processing and analysis, storage, Disclosure, Deletion and/or Destruction of Personal Data and/or other information.
• " Destruction" is an activity aimed at eliminating Your Personal Data, either entirely or partially, in Our electronic and non-electronic systems that cannot be accessed again in the future.
• " Deletion" is an activity aimed at restricting the use of Your Personal Data, either entirely or partially, in Our electronic and non-electronic systems that can be accessed again in the future for the purposes set out in this Privacy Policy.
• " Disclosure" or " Disclose", depending on the context and sequence of words used in a sentence, is the display, announcement, delivery, dissemination, and/or opening of access to Your Personal Data and/or other information.
• " Third Party" are parties, such as, among others; Competent Authorities, Our partners, contractors, vendors, agents, Our Affiliate companies.

ACQUISITION AND COLLECTION OF PERSONAL DATA

• We obtain Your Personal Data depending on your use of Our Service, the Personal Data We obtain includes but is not limited to:
  • General Personal Data;
    • Your Name
    • Your Phone Number
    • Your Email
  • Sensitive Personal Data;
    • Your financial data
    • Your physical data (including your facial form/face)
• We obtain and collect Your Facial Data in the following ways:
  • Direct submission by You:
    • When you use and register your face from the application
    • Facial data will be used for the attendance verification process in the application.
    • If the face owner matches, all attendance procedures are fulfilled.
    • Facial Data is only used for the facial attendance procedures agreed upon by the Company and us as the application provider.
    • The stored facial data is not a face photo, but facial vector data converted into coordinates.
    • Facial data will remain stored as long as the user is an employee of the company cooperating with us as the application provider.
    • Facial data will be deleted if the employee has resigned as an employee or ceases to be an employee of the company cooperating with us as the application provider.
    • The person responsible for all facial data in the application is the PIC (personal contact information) appointed by the company itself.
• We obtain and collect Your Personal Data in the following ways:
  • Direct submission by You, such as, among others:
    • When you contact Our Contact;
    • When you update your Personal Data previously stored by Us;
    • Filling out surveys sent by Us or other parties officially appointed to represent Us;
    • Using features on the Service that require permission to access relevant data stored on your device.
    • Using services on the Service, including detailed transaction data, among which are the type, quantity and/or description of the product or service purchased, delivery address, payment channel used, transaction amount, transaction date and time, and other transaction details;
    • Filling in payment data when you carry out payment transaction activities through the Service, including but not limited to bank account data, credit card, virtual account, instant payment, internet banking, retail outlets; and/or
  • Data recorded when you use the Service, including but not limited to:
    • Real or estimated location data such as IP address, Wi-Fi location and geo-location;
    • Data in the form of time of each of your activities related to the use of the Service;
    • Data on your usage or preferences, including your interactions in using the Service, saved choices, and selected settings. This data is obtained using technology that creates and maintains unique identifiers;
    • Device data, including the type of device used to access the Service, including hardware model, operating system and its version, software, IMEI number, file name and version, language choice, unique device identifier, advertising identifier, serial number, device motion information, and/or cellular network information; and/or
    • Log data, including records on servers that receive data such as device IP address, date and time of access, application features or pages viewed, application work processes and other system activities, browser type, and/or third-party sites or services you used before interacting with the Service.
  • Data obtained from other sources, including but not limited to data in the form of emails from marketing service providers.
  • Acquisition and collection from Third Parties that store Your Personal Data; and
  • Acquisition and collection by other means and from any source as available and as long as it is not prohibited by applicable laws and regulations.
• You hereby know and agree to provide and authorize Us to obtain and collect Your Personal Data and/or other related data or information by the means referred to in letter a above for the purposes set out in this Privacy Policy.
• You must always ensure that the Personal Data you submit to Us is true, complete, accurate, and not misleading. You must notify Us if there are changes to Your Personal Data before such changes become effective, or according to the provisions set out in the agreement you have with Us governing changes to Personal Data. Any incompleteness, invalidity, inaccuracy, and/or misleading nature of Your Personal Data submitted to Us may constitute a failure to comply with legal requirements. Furthermore, you hereby release Us from all consequences arising from your negligence or error in maintaining the truth, completeness, and accuracy of Your Personal Data, and your failure to maintain the validity, completeness, accuracy of the Personal Data submitted to Us.
• In submitting Personal Data, you hereby declare and warrant that you are a party legally competent to submit Personal Data to Us, and if:
  • You are an individual under 21 (twenty-one) years of age and have never been married, then We assume that the submission of Your Personal Data has been approved by your parent, guardian, or legitimate custodian to represent you;
  • You are a party in the form of a body or entity, then We assume that the submission of Your Personal Data is carried out by a legitimate representative to submit Your Personal Data to Us, such as, among others; attorney-in-fact or director; and
  • You are an individual who is legally competent but the submission of Your Personal Data is represented by an attorney-in-fact, then We assume that the submission of Your Personal Data is carried out by an attorney-in-fact that you have validly appointed to represent you.

PURPOSE OF PERSONAL DATA PROCESSING

We may use the Personal Data obtained and collected from you as mentioned in the previous section for the following matters:

• Providing features to provide, realize, maintain and improve our products and services.
• Sending information that We consider useful for you, namely information about Our services or Third Parties cooperating with Us, updates, development, and/or improvement of Our services or facilities.
• Personalizing the Service for your maximum benefit provided by Us and/or Third Parties that have cooperated with Us.
• Our compliance with obligations imposed by Competent Authorities or applicable laws and regulations as suggested, recommended, expected or requested to do so by Our legal advisors and/or Competent Authorities, which includes disclosures made in accordance with court summons, decisions and/or orders, orders from law enforcement authorities in the context of investigation or other legal processes or requirements applicable to Us or Our Affiliates.
• Processing your requests regarding access, correction, updating, and/or Deletion/Destruction of Your Personal Data in Our system, and to contact you regarding your request to Us.
• Other purposes as long as such purpose is not prohibited by applicable laws and regulations. To avoid doubt, We will notify you of such other purposes when requesting your consent, unless otherwise stipulated by applicable laws and regulations.
• Assisting you when communicating with Our customer service, including to:
  • Check and resolve your problems;
  • Direct your questions to the appropriate customer service officer to resolve the problem;
  • Contact you via email, mail, phone, fax, and other communication methods, including but not limited to, to assist and/or complete the troubleshooting process, and convey other news or notifications related to the protection of Your Personal Data by Us, including failure to protect Your Personal Data;
  • Use information obtained from you for research, analysis, development and product testing purposes to improve the security of services on the Service, as well as develop new features and products; and
  • Inform you about products, services, promotions, studies, surveys, news, latest developments, events and other information, either through the Service or through other media. We may also use such information to promote and process contests and lotteries, provide prizes, and present relevant advertisements and content about Our services and business partners.
• In certain circumstances, We may need to use or disclose Your Personal Data for law enforcement purposes or to fulfill the requirements and obligations of applicable laws and regulations, including in the event of a dispute or legal process between you and Us, or alleged criminal acts such as fraud or data theft.

DISCLOSURE OF PERSONAL DATA

• We sometimes must Disclose Your Personal Data for the following purposes and other purposes permitted by applicable laws and regulations:
  • Fulfilling obligations, responsibilities, or orders arising from applicable laws and regulations or orders from Competent Authorities including but not limited to; needs for investigation or inquiry, fulfillment of court orders for a legal process, or to comply with archival or reporting obligations based on a law, and for other purposes as required by applicable laws and regulations.
  • Carrying out the public interest. We may provide Your Personal Data to Competent Authorities and/or other parties appointed by Competent Authorities, for purposes, including but not limited to; contact tracing, supporting initiatives, policies or programs of Competent Authorities, and other purposes as reasonably needed.
  • Merger, consolidation, acquisition, restructuring activities, the implementation of which involves Us as the party carrying out such activities with another party or over another company or Us as the party being merged or consolidated with another company or acquired by another company.
  • Use of Personal Data by Third Parties in the context of providing, testing, researching, analyzing, selling, marketing, offering, or improving the quality of Our products or services. Third Parties that cooperate with Us which in such cooperation require the sending and/or Disclosure of Your Personal Data. Such products or services include the following: marketing services and service providers that handle complaints.
  • Implementation of cooperation with Third Parties in order to (i) assist Us in providing Our services; (ii) operate Our business; (iii) for the purpose of Processing data on Our behalf; (iv) marketing, and (vi) other purposes as long as not prohibited by applicable laws and regulations. All Third Parties cooperating with Us are committed to processing the Personal Data they receive from Us in accordance with applicable laws and regulations.
• In connection with the Disclosure of Your Personal Data to Third Parties, including from Third Parties to other parties, We will require such Third Parties and other parties to maintain the security and confidentiality of Your Personal Data in accordance with the provisions of applicable laws and regulations. If the relevant Third Party does not need certain Personal Data to be associated with You, the relevant Personal Data will be reasonably deleted so that such Personal Data cannot be associated with you as an individual before being disclosed or transferred to such Third Party. However, such other third parties will only manage and/or utilize Your Personal Data in connection with one or more purposes as set out in this Privacy Policy and in accordance with the provisions of applicable laws and regulations.

COLLECTION OF PERSONAL DATA FROM THIRD PARTIES

• We may also collect Your Personal Data from Third Parties that have cooperation with Us. In such cases, We will only collect Your Personal Data for purposes involving such Third Parties or for the purpose of implementing Our cooperation with such Third Parties.
• If We receive Your Personal Data from a Third Party, then We assume that the submission of Your Personal Data to Us by such Third Party has been previously approved by you so that We cannot be held liable in any form if such Third Party submits Your Personal Data without your prior consent.
• Our Service may contain links to Third Party sites. We are not responsible for the acquisition, collection, processing, analysis, use, storage, display, announcement, delivery, dissemination, deletion and destruction of Your Personal Data by such Third Parties. If you provide information directly to such sites, the privacy policy and terms of service on that site will apply, and We are not responsible for the information processing activities or privacy policies of that site.

PERSONAL DATA SECURITY

• We will protect and secure Your Personal Data, stored in Our storage systems (which includes limiting access to Your Personal Data to Our employees on a need-to-know basis. Processing of Your Personal Data will only be done in a manner permitted and required to maintain the confidentiality of Your Personal Data) from Processing of Personal Data by unauthorized parties and from Processing of Personal Data contrary to applicable laws and regulations, unintentional loss, destruction and damage or similar unintentional risks by taking and implementing reasonable legal, organizational and technical measures.
• Storage of Personal Data by Us:
  We will store Your Personal Data in Our storage systems, for as long as:
  • Storage of Your Personal Data is necessary to fulfill the purposes as intended in this Privacy Policy;
  • Storage of Your Personal Data is permitted or required by applicable laws and regulations;
  • During the retention period we set and permitted by applicable laws and regulations;
  • You do not request Deletion/Destruction of Your Personal Data stored by Us or you do not withdraw your consent for Us to store Your Personal Data; and/or
  • Your request for Deletion/Destruction of Your Personal Data stored by Us has been rejected by Us based on considerations set out in this Privacy Policy.
• Personal Data stored by Competent Authorities:
  • We may be required by applicable laws and regulations and/or Competent Authorities to send or share Your Personal Data to Competent Authorities and/or other parties appointed by Competent Authorities.
  • In connection with point (i) above, you hereby agree and acknowledge that the storage of Your Personal Data by Competent Authorities and/or other parties appointed by Competent Authorities will follow the data storage policies and standards applied by such Competent Authorities and/or other parties appointed by Competent Authorities.
  • You hereby know and agree that We are not responsible for the security and confidentiality of Your Personal Data stored by Competent Authorities and/or other parties appointed by Competent Authorities, and release Us from all claims related to breaches of security and confidentiality of Your Personal Data stored by Competent Authorities and/or other parties appointed by them.
• Precautionary principle:
  • We strongly urge you to be very careful in maintaining the security and confidentiality of Your Personal Data, by, among others:
    • Paying close attention to the media you use to store, upload, convey, transmit, and/or share Your Personal Data; and
    • Applying the precautionary principle by at least signing a confidentiality agreement with the party you trust to receive and store Your Personal Data, or requiring such party to have and apply a privacy policy/notice that does not conflict with applicable laws and regulations, and only entrusting the storage of Your Personal Data to parties that have credibility and integrity in protecting Personal Data.
  • Use of internet network: you need to know that the use of the internet network for sending, sharing, uploading, or conveying Your Personal Data is not entirely secure, considering that the internet network can be accessed by any party and there are risks related to the provision and utilization of the internet network that are beyond Our control and supervision. The provision of Personal Data by you will be at your own risk. Please always be careful in utilizing the internet network for the benefit of Your Personal Data at all times you utilize the internet network.
• Exclusion of liability: We cannot be held liable in any form for:
  • The security and confidentiality of Your Personal Data that you store yourself or that you submit to Third Parties or other parties;
  • The security and confidentiality of Personal Data that has been Disclosed to the public or Third Parties, whether the Disclosure is made by you or any party other than Us, and such Disclosure occurs not due to Our negligence or error in protecting Your Personal Data;
  • All consequences arising from negligence you commit in maintaining the security and confidentiality of Your Personal Data; and
  • All consequences arising from the use of any media you use to store, upload, convey, transmit, and/or share Your Personal Data, such as, among others; internet network and cloud storage services.
• We protect all Your Personal Data stored in its system, and protect such data from unauthorized access, use, modification, retrieval and/or disclosure by using a number of security actions and procedures.
• Your Personal Data may also be stored or processed outside the country by parties working for Us in other countries, or by third-party service providers, vendors, suppliers, partners, contractors, or Our affiliates. In such cases, We will ensure that such Personal Data remains protected in accordance with Our commitments in this Privacy Policy.
• Although We have used Our best efforts to secure and protect Your Personal Data, it is known that data transmission over the Internet is never completely secure. Thus, We cannot guarantee 100% security of data provided or transmitted to Us by you and the provision of information by you is a risk borne by you yourself.
• We will delete Your Personal Data under Our control if (i) Your Personal Data is no longer necessary to fulfill the purpose of its collection; (ii) it has passed the retention period according to the provisions we set; and/or (iii) storage is no longer required for the purpose of compliance with applicable laws and regulations.
• Please note that it is still possible that some of Your Personal Data is stored by other parties, including authorized state administration agencies. In the event We share Your Personal Data with authorized state administration agencies and/or other agencies that may be appointed by the authorized government or have cooperation with Us, you agree and acknowledge that the storage of Your Personal Data by such agencies will follow the respective data storage policies of such agencies.

ACCESS, CORRECTION, AND UPDATING OF PERSONAL DATA

• You can request Us to:
  • provide Your Personal Data and/or give you access to Your Personal Data stored in Our storage systems;
  • correct Your Personal Data stored in Our storage systems; and/or
  • update Your Personal Data stored in Our storage systems.
• If We provide Your Personal Data to you, such provision will be carried out electronically and Your Personal Data will be provided in electronic form or by other means of provision and in other forms as We determine from time to time.
• We have the right to refuse your request as referred to in letter a above in part or in whole, if:
  • your request is not relevant to Your Personal Data stored by Us, such as, among others; if you request Personal Data of another party for which you are not authorized over such Personal Data; and/or
  • We are not permitted by Competent Authorities and/or applicable laws and regulations to carry out your request.
• You are obliged to update Your Personal Data, if you make changes to Your Personal Data that you have submitted to Us. We need you to update Your Personal Data for security and relevance purposes of Personal Data.
• We may charge an administrative fee to you for handling your request to access or correct Your Personal Data.
• You can withdraw the consent you have given regarding the processing of Your Personal Data under Our control by submitting such request in writing through Our customer service listed in this Privacy Policy. We will process your request within a reasonable period from the submission of the withdrawal of consent request, and subsequently not process Your Personal Data in accordance with your initial request, unless required by applicable laws and regulations.

CONSENT

• By agreeing to the Privacy Policy, you acknowledge and declare that you have read and understood the provisions in this Privacy Policy. In particular, you give Us consent to carry out Processing of Your Personal Data in accordance with the provisions in this Privacy Policy.
• You are deemed to have given your consent to the applicability of this Privacy Policy to you if one or more of the following conditions occur:
  • You visit and/or use Our Service and/or use the facilities provided by Us;
  • You submit Your Personal Data to Us for the purpose of Processing Your Personal Data as intended in this Privacy Policy;
  • Your Personal Data is stored in Our storage systems; and/or
  • conduct communication with Us.
• This Privacy Policy becomes effective from the moment you give your consent to this Privacy Policy, either expressly or by the methods mentioned in letter b above, and will continue to be in effect as long as one of the conditions mentioned in letter b above occurs or until you withdraw your consent.
• If you are given the option to share Your Personal Data with Us, you can always choose not to do so. If We have requested your consent to Process and you then choose to withdraw your consent, We will respect that choice in accordance with Our legal obligations. However, choosing not to share Your Personal Data with Us may mean that We cannot take the necessary actions to achieve the purposes of Personal Data Processing as set out in this Privacy Policy or that you cannot use the Service.

DELETION/DESTRUCTION OF PERSONAL DATA AND WITHDRAWAL OF CONSENT

• Your Personal Data collected by Us will be stored securely for as long as you use Our Service to fulfill the purposes described in this Privacy Policy.
• You have the right to withdraw your consent for Us to store Your Personal Data and with such withdrawal of consent, We will delete/destroy Your Personal Data from Our storage systems and stop Processing Your Personal Data.
• In addition to based on the provisions in letter a above, Your Personal Data can also be deleted/destroyed from Our storage systems, if:
  • You stop using or subscribing to Our Service. To guarantee data availability and backup, We will carry out Deletion/Destruction of Your Personal Data no later than 1 (one) year after We receive notification of termination of subscription to Our Service;
  • Your Personal Data is no longer needed and the Deletion/Destruction of such Personal Data is permitted by applicable laws and regulations;
  • You request Us to delete/destroy Your Personal Data stored in Our storage systems in part or in whole, by sending a written request to Our Contact; and/or
  • We are prohibited from storing Your Personal Data based on applicable laws and regulations and/or orders from Competent Authorities.
• We have the right to refuse your request for Deletion/Destruction of Your Personal Data, as referred to in letter a above, in part or in whole, if:
  • Your Personal Data has been deleted/destroyed by Us in Our storage systems based on your similar previous request, and/or request from Competent Authorities to Us;
  • Your request is not relevant to Your Personal Data stored by Us, such as, among others; if you request Personal Data of another party for which you are not authorized over such Personal Data; and/or
  • We are not permitted by Competent Authorities and/or applicable laws and regulations to carry out your request.
• In connection with this Deletion/Destruction, and withdrawal of consent, you hereby agree that you release Us from any responsibility for all consequences arising from such Deletion/Destruction, and withdrawal of consent.

THIRD-PARTY PLATFORMS

• You need to know and understand that Our Service may contain links to Third-Party platforms, such as, among others; advertisements or widgets that if you click may take you to Third-Party platforms.
• You acknowledge and agree that Third-Party platforms are managed and operated independently by such Third Parties, and We will be released from all liability for the Processing of Your Personal Data by Third Parties, as referred to in letter a above.
• If you provide Your Personal Data to Third Parties through these Third-Party platforms, you agree that the privacy policy/notice and terms of service on such platforms will apply, and We will be released from all liability for Personal Data Processing activities carried out by such Third Parties or regulated based on the privacy policy/notice and terms of service on such platforms.

MARKETING AND PROMOTIONAL MATERIALS

• In connection with your use of Our Service, you agree that We and/or Third Parties cooperating with Us may use identifying technologies to collect Your Personal Data for purposes not prohibited by laws and regulations.
• You agree that We and/or Third Parties cooperating with Us may send you direct marketing and promotional materials such as; advertisements and/or promotional communications, via email or other communication means as available.
• You have the right to choose not to receive such marketing and promotional materials to your email or contact, as referred to in letter b above, by:
  • pressing the unsubscribe button on the marketing and promotional materials you receive;
  • disabling the notification and location services from your device; and/or
  • contacting Our Contact and stating your objection regarding the sending of such marketing and promotional materials to your email or contact.

OVERRIDE

In this Privacy Policy, a special override applies to facial structure data. Regarding your facial structure data, the following provisions shall apply:

• Disclosure to Third Parties.
  Regarding Disclosure of Personal Data to Third Parties, it does not include Disclosure of your facial structure data.
• Deletion/Destruction.
  In the event you stop using or subscribing to Our service, specifically for facial structure data, it will be deleted/destroyed no later than 3 (three) months after we receive notification of termination of subscription to Our Service.

OTHER PROVISIONS

• Changes:
  • We may review and change this Privacy Policy at Our own discretion to ensure that the provisions in this Privacy Policy are consistent with Our future developments, and/or if there are changes in laws and regulations and/or orders from Competent Authorities for Us to change the provisions in this Privacy Policy.
  • We will notify you of changes as referred to in point i above through public notice on Our Service, or through special notice to your email address or contact registered in Our system.
  • You agree that you are solely responsible for periodically reviewing this Privacy Policy to know the latest information regarding this Privacy Policy through Our Service and/or on your email and/or contact registered on Our Service. Please periodically and regularly visit Our Service so that you can be informed about Our Privacy Policy from time to time.
  • By you continuing to:
    • visit and/or use Our Service and/or use the facilities provided by Us;
    • submit Your Personal Data to Us for the purpose of Processing Your Personal Data as intended in this Privacy Policy;
    • have Your Personal Data stored in Our storage systems; and/or
    • conduct communication with Us.
  • it means you agree to the changes We have implemented.
  • You are obliged to ensure that your contact that you register with Us is correct and always active to avoid failure in delivering notifications to you.
• Invalidity: The invalidity of a provision in this Privacy Policy due to the enactment of a law or other reasons will not automatically invalidate the applicability of other provisions in this Privacy Policy.
• Our Contact: If you have questions or complaints regarding the implementation of this Privacy Policy, you can contact Us through Our Contact listed below:
  • Phone number: +628535-9999-888;
  • Email: support@cybernet.co.id
• Language: The Privacy Policy is made in Indonesian.
• Governing Law: All provisions in the Privacy Policy are subject to and interpreted in accordance with the laws applicable in the territory of the Unitary State of the Republic of Indonesia.
• Version: This Privacy Policy was last updated on October 30, 2025. Please check this Privacy Policy periodically for any changes.