INTRODUCTION

We, ELLE Indonesia (PT Elia Mediatama Indonesia), as subsidiaries or holding company, and any subsidiary of any such holding company (collectively referred to as “We”, “Us” or “Our”), respects the privacy of our users. As an individual who is a user of our website (www.elle.co.id) (“Site”); and all associated web pages and mobile applications provided by us (“Online Services”), this Privacy Policy is intended to describe for you:

• the information we collect from you;
• how we will use the information collected from you;
• with whom the information may be shared;
• how you may access the information you provide us; and
• your choices about such uses and disclosures.

We encourage you to read this Privacy Policy carefully before using the Online Services. By using the Online Services, you consent to the collection and use of information in accordance with this Privacy Policy.

If you have any questions about this Privacy Policy, please refer to the contact details found at the end of this Privacy Policy for information on how to contact us.

Information We Collect About You

We may collect and process the following information about you:

• information (such as your e-mail address, home or mailing address, telephone number, gender, and age) that you provide by completing online forms, including if you register as a user of the Online Services, receive our newsletter(s), upload or submit any material via the Online Services, request any information or enter into any competition or promotion we provide
• in connection with your account, your log-in, and password details
• details of any transactions made by you through the Online Services
• communications you send to us, for example, to report a problem or to submit queries, concerns, or comments regarding the Online Services and its content
• information from surveys, promotions, and competitions that we may, from time to time, run via the Online Services, if you choose to respond to, or participate in, them
• details of your uses of the Online Services, the resources you access, and any data you download
• technical information from your computer or mobile device relating to the services you receive
• information that you post in the form of comments or contributions to discussions
• personal data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorized representatives)
• information that does not identify you

When you provide personal data to us whether through the Online Services or otherwise, the information may be sent to servers located in and/or outside Indonesia.

Purposes that We Collect, Use, Disclose and Process Personal Data

In general, we may collect, use, disclose and/or process personal data for various purposes including the following:

• Identify you when you sign in to your account or verify your identity
• Administer your account with us
• To communicate with you, or to respond to your queries, requests and/or complaints;
• To provide you with updates on any administrative changes, and/or amendments to our policies, terms and conditions;
• Conducting and completing transactions (e.g. providing products or services that have been requested by users)
• Providing customer service (e.g. responding to queries and requests; informing users about service/application/processing statuses and product updates)
• Sending alerts and newsletters as requested by users
• Organizing events, conducting market research, and improving customer service
• Conducting marketing promotions (e.g. sending of alerts, newsletters, marketing materials, and invitations from us wholly or through affiliation with third parties)
• Complying with applicable laws, regulations, and other requirements
• to protect against or identify possible fraudulent transactions
• Performing of evaluations (e.g. assessing the suitability of employees)
• Protect and enforce our contractual and legal rights and obligations
• comply with any applicable laws and regulations or to assist in law enforcement and/or investigations by any governmental authority, public agency, statutory board, or similar authority;
• For any other purposes which we notify you of at the time of obtaining your consent.

We will only use, disclose and/or transfer personal data in accordance with the above purposes, or for purposes that are permitted under applicable laws and regulations.

Third Parties

We may share your personal data with our authorized service providers that perform certain services on our behalf or who display advertisements on the Online Services. These service providers may include companies that support surveys or other features offered through the Online Services, or that provide business analysis or website support. These service providers may have access to personal data needed to perform their functions or gauge the effectiveness of targeted advertisements but are not permitted to share or use such information for any other purpose.

Security

We regard breaches of privacy very seriously and have implemented measures to secure and protect the information, such as training our employees who handle personal data to respect the confidentiality of such personal data, storing personal data in a combination of secure computer storage facilities and paper-based files and other records, taking steps to protect the personal data we hold from misuse, loss, unauthorized access, modification or disclosure.

We cannot, however, secure personal data from cyber-attacks, such as hacking, spyware, and viruses, and cannot be held liable for any unauthorized disclosure, loss, or destruction of personal data arising from such risks.

Overseas Transfers

The information you provide may be transferred to countries outside Indonesia that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy. However, we will take steps to ensure adequate protections are in place to ensure the security of your information.

Visiting the Online Services from Outside Indonesia

This Privacy Policy is intended to cover the collection and use of information from those who access the Online Services from Indonesia. If you are visiting the Online Services from outside Indonesia, please be aware that your information may be transferred to, stored, and processed in Indonesia where our servers are located and our central database is operated. The data protection and other laws of Indonesia and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy policy.

Accessing your information and updating/correcting your information

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal data, please contact us at the contact details found at the end of this Privacy Policy. We may make a small charge for this service.

We want to ensure that your personal data is accurate and up to date. If any of the information that you have provided to us changes, for example, if you change your email address or name, or if you wish to cancel your registration, please let us know the correct details by contacting us at the contact details found at the end of this Privacy Policy.

To be informed of the personal data we possess, as given to us by individuals, a verification of identity will be required of the party requesting the information. Disclosure is made only to the individual to whom the personal data pertains to.

Withdrawing Consent to Our Access to Your Personal Data

To make a request to withdraw consent previously given, please contact us directly at the contact details found at the end of this Privacy Policy. All requests to have personal data removed from our databases or physical storage facilities will be entertained and performed within our reasonable abilities.

Retention of Personal Data

We will not store personal data longer than necessary. We will cease to retain the personal data when it is no longer required for the purposes that the personal data was collected.

Cookies

When you use the Online Services, we may assign your computer and/or mobile device one or more cookies to facilitate access to the Online Services, to personalize your online experience, and to record information about your use or access. Through the use of cookies, we may also automatically collect information about your online activity on the Online Services, such as the web pages you visit, the links or advertisements you click, or the other actions you conduct while using or accessing the Online Services. The cookies do not store any personally identifiable information about you. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the features offered on our Online Services.

Other Technologies

We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of the Online Services. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer on the Online Services to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming, or other activities.

Aggregated and Non-Personal data

We may share aggregated information (i.e., information about you and other users collectively, but not specifically identifiable to you) and other non-personal data we collect under any of the above circumstances. We may also share it with third parties to develop and deliver targeted advertising on the Online Services and on the websites or mobile applications of third parties. We may combine the non-personal data we collect with additional non-personal data collected from other sources. We may also share aggregated information with third parties, including advisors, advertisers, and investors, for the purpose of conducting general business analysis. For example, we may inform our advertisers or investors of the number of visitors accessing the Online Services and the most popular features of the Online Services accessed. This information does not contain any personal data and may be used to develop content and services that we hope you and other users will find of interest.

Third-Party Websites

You may be able to access other third-party websites that do not operate under this Privacy Policy. For example, if you click on an advertisement or a search result on the Site, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal data, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit.

No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal data relating to users of the Online Services.

Changes to This Privacy Policy

We will occasionally update or amend this Privacy Policy to reflect changes in our practices and services by prominently posting notice of the updates or changes to the Online Services. By continuing to use and access the Online Services following such updates or changes, you agree to be bound by any updates or changes made by us.

How to Contact Us

If you have any questions about this Privacy Policy, our information-handling practices, or our disclosure of personal data to third parties, please contact us here.