Privacy Policy
Hello, welcome to Rey!
PT Vertika Technologies Nusantara (“Rey” or “We”) is committed to safeguarding and responsibly using your Personal Information with great care. By engaging in activities such as downloading, using, accessing the Dashboard, Platform, and/or Rey Services, You acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy and accept all potential risks that may arise from your actions. For reference, “You” in this Privacy Policy refers to Users, Members, and Service Providers on the Rey Platform.
This Privacy Policy constitutes a valid and binding agreement between You and Rey. For Users and Members, this Privacy Policy is an integral part of Rey Membership's Terms and Conditions. This Privacy Policy governs how Rey processes your Information, which includes the acquisition, collection, processing, analysis, storage, improvement, updating, display, announcement, transfer, dissemination, disclosure, deletion, and/or destruction of your Personal Information that we carry out.
The matters covered in this Privacy Policy include:
A.
Your Information;
B.
Collection of Your Information;
C.
Use of Your Information;
D.
Disclosure of Your Information;
E.
Storage of Your Information;
F.
Information Regarding Minors, Those Under Guardianship, and Persons with Disabilities;
G.
Accuracy and Correction of Your Information;
H.
Your Rights;
I.
Legal Basis for Processing Your Personal Information;
J.
Other Provisions; and
K.
Contact Us
If You do not agree with this Privacy Policy, You are advised to stop downloading, using, and/or accessing the Rey Platform and/or Services.
A.
Your Information
The information collected when You download, use, or access the Rey Platform and/or Services includes:
1.
Your Personal Information
This includes your full name, gender, nationality, religion, marital status, address, phone number, date of birth, identity card (KTP), health data and information, child data, combined personal data, and email address that you provide when becoming a Member on our Platform.
2.
Your Legal Entity Information
If You are a Legal Entity, your information includes the legal entity’s name, the name of the responsible person, type of legal entity, address, articles of incorporation, articles of association, amended articles, Business Identification Number (NIB), Taxpayer Identification Number (NPWP), and other relevant documents.
3.
Member’s Personal Health Information
This includes the Member's personal health information, including but not limited to known health conditions, treatments, allergies, vaccinations, medical history, health goals, health journal entries, reports, lab results, and medical records uploaded by the Member from time to time on the Platform. For clarity, the Member’s personal health information does not include claim-related health information required for claim submissions through the Rey Platform, as described in Section B, Clause 5 regarding Claim Information Copies, unless otherwise specified by the Insurance Company as the provider of Rey's Insurance Products.
4.
Business Information from Service Providers
This includes the business profile and healthcare services you provide to users on the Rey Platform.
B.
Collection of Your Information
We may obtain or collect your information through the following methods:
1.
Direct Collection of Information from You
You may provide your information directly to Rey when we request it from You or as required by applicable laws, whether during your direct interaction with Rey or through correspondence via mail, email, or other means. This includes information you provide when including but not limited to:
a.
Registering and creating an account to become a Rey Member;
b.
Making payments to become a Rey Member;
c.
Using the Services on the Rey Platform;
d.
Contacting and/or interacting with Rey;
e.
Filling out and/or submitting any forms or surveys related to the Rey Platform and/or Services;
f.
Participating in activities conducted by Rey, whether online or offline;
g.
Using features within the Rey Services that require permission to access your device; and
h.
Any other information you disclose or provide directly to Rey.
2.
When You Use the Rey Platform and/or Services
Rey may obtain or collect your information when You use the Rey Platform and/or Services, including but not limited to:
a.
Location data, including but not limited to IP address, Wi-Fi location, geo-location, GPS coordinates, fitness data, device type, and other information provided by your device;
b.
Your activity data while using the Rey Platform, including but not limited to account creation and registration, payments, use of Rey Services, and other activities you may perform through the Rey Platform;
c.
Settings or configurations on the Rey Platform;
d.
Hardware and software data used to access or use the Rey Platform and/or Services; and
e.
Log files when you access or use the Rey Platform and/or Services.
3.
From Other Third Parties
Rey may obtain or collect your Personal Information from other third parties, including but not limited to:
a.
Partners and/or Insurance Partners working with Rey to provide Services for Rey Members;
b.
Parties cooperating with Rey to promote the Rey Platform and/or Services;
c.
Other sources are publicly available or in the public domain and processed by Rey.
4.
Third-Party Information Provided by You
Rey may obtain or collect Personal Information of third parties provided by You to Rey, including but not limited to information about your spouse, family members, friends, or others. You hereby represent and warrant that You have obtained the consent of these individuals and are entitled to provide their information to be managed by Rey.
5.
Copies of Claim Information
By using the claim submission services on the Rey Platform, the Member consents to Rey storing copies of claim information and/or other data related to the claim information to be used as outlined in Section C. In this Privacy Policy, copies of claim information include:
a.
Examination results reports;
b.
Payment receipts;
c.
Laboratory test results (if any); and
d.
Emergency case statements (if any).
C.
Use of Your Information
1.
We will use your information to enhance services for marketing, education, statistics, and scientific purposes, as well as for specific and limited purposes, including but not limited to:
a.
Addressing and contacting You regarding the resolution of complaints, inquiries, or disputes involving You;
b.
Informing You about matters related to your use of the services available on our Platform;
c.
Developing and improving our Services and/or Platform functionalities;
d.
Verifying and ensuring the accuracy of data or the identity of individuals contacting us via phone, electronic tools, or other forms of communication;
e.
Legal purposes and compliance with regulations under Indonesian law;
f.
Understanding and assessing your interests, needs, and changing preferences;
g.
Customizing your preferences or experience when using our Platform;
h.
Processing Members' Personal Health Information to monitor and provide benefits or other additional purposes;
i.
Conducting any activities related to Rey’s internal compliance regulations, including those related to Rey’s policies and procedures;
j.
As reasonably required for third-party service agreements or approvals;
k.
Emergency Contact Information;
l.
Providing offers for services we facilitate based on partnerships between us and other third parties; and
m.
Any other purpose required or authorized by Indonesian law.
n.
Ensuring data security and fraud prevention measures are in place.
2.
We may also use your Personal Information and other data for marketing purposes, both digitally and conventionally, which include:
1.
By downloading and/or using the Rey Platform and Services, You agree that You have read, understood, and accepted the applicable Terms and Conditions. These Terms and Conditions constitute a legal agreement between You and Rey and apply each time You access the Rey Platform and Services (as defined in these Terms and Conditions).
2.
By using these Services, You agree that:
a.
Digital marketing includes but is not limited to:
i.
Paid digital media advertising;
ii.
Social Media Influencers;
iii.
Radio ads, including but not limited to adlibs, spots, inserts, and semi-blocking;
iv.
Search Engine Optimization (SEO);
v.
Search Engine Marketing (SEM); and
vi.
Social media.
b.
Conventional marketing includes but is not limited to sending emails related to service offers, service updates, surveys, or other matters we deem appropriate based on your needs or interests.
c.
You may opt out of any marketing materials and/or offers we email you.
3.
When you use the Rey Platform and/or Services outside the Republic of Indonesia (“Other Countries“), Rey may transfer your information to Other Countries to allow You to use the Rey Platform and/or Services in those countries.
4.
Your information may be processed in Other Countries by Rey, including but not limited to personnel, partners, affiliates, Service Providers, and other parties, and Rey will make every effort to ensure that the processing of your information will have a level of protection equivalent to this Privacy Policy and under the applicable laws of Other Countries.
D.
Disclosure of Personal Data
1.
Rey may disclose or grant access to your Information to affiliates or other parties for the following purposes:
a.
Enabling You to access, use, or enhance the Services and allowing Service Providers to deliver Services on the Rey Platform;
b.
Conducting verification processes reasonably required by us, the Service Providers, or other third parties before You can access or use the Rey Platform and/or Services;
c.
Processing claims with Service Providers or Insurance Companies;
d.
In advertising, we may disclose your Information to advertisers and ad networks to select and offer relevant ads to You;
e.
In emergency situations regarding your safety (whether you are a user or a Service Provider) to handle such emergencies;
f.
Disclosure for internal investigation purposes regarding possible criminal acts or violations of applicable laws, regulations, or policies within Rey and/or its affiliates;
g.
Disclosure in legal proceedings of any kind between us and You or other third parties related to the Rey Platform and/or Services;
h.
Disclosure to third parties, including but not limited to agents, vendors, suppliers, contractors, partners, and other parties, aimed at providing Services to us and/or You;
i.
Disclosure to our affiliates or business group, including but not limited to parent companies and subsidiaries, to support the operation of the Rey Platform and/or Services;
j.
Disclosure for the purposes of mergers, asset sales, consolidations, restructurings, financing, and/or acquisitions of all or part of our business;
k.
When requested, instructed, required, or permitted by competent authorities for purposes stated in government policies, regulations, or applicable laws in Indonesia;
l.
When permitted, required, or authorized by legislation for purposes specified in applicable laws in Indonesia;
m.
Disclosure reasonably necessary to perform the activities mentioned in Section C.
2.
When You use or access the Rey Platform, You acknowledge that cookies may be stored on your device to retain your preferences or configurations while using or accessing the Rey Platform. Cookies will not affect your device except for other purposes You have agreed to. You can set your web browser to reject cookies, but this may hinder the availability of Services on the Rey Platform.
3.
In disclosing any Information to third parties, Rey will make reasonable efforts to avoid associating and/or disclosing your Information in such disclosures.
4.
Rey will not sell, rent, and/or use your Information for any purpose other than improving Services, marketing, education, scientific purposes, and facilitating the use of the Rey Platform and/or Services.
E.
Storage of Your Information
1.
As permitted by applicable laws, all Information you disclose to Rey will be stored under the following conditions:
a.
As long as You access or use the Rey Platform and/or Services;
b.
During a grace period after You stop accessing and/or using the Rey Platform or after You request the deletion of your Information, or
c.
In accordance with the purpose for which your Information was collected.
2.
We will delete and/or anonymize your Information when it is no longer needed to fulfill the purpose for which it was collected or is no longer required for compliance with applicable regulations.
3.
Please note that your Information may be stored by other third parties, including authorized government institutions. In the event we disclose your Information to government institutions and/or other agencies appointed by the government or other third parties collaborating with us, You agree and understand that the storage of your Information by the government, agencies, and/or third parties will follow the respective party’s information storage and privacy policies.
F.
Information of Minors, Wards, and Persons with Disabilities
1.
You may provide Information regarding your children or relatives, including but not limited to children under 18 years old, unmarried, and under your guardianship, or individuals with disabilities under your care, when accessing or using the Rey Platform and/or Services.
2.
By agreeing to provide Information about minors and individuals under your guardianship, You agree and understand that as their parent or guardian, You are fully responsible for the disclosure, use, and submission of their Personal Information and any legal consequences arising from it.
G.
Accuracy and Correction of Your Information
1.
The Information You provide to us must be as accurate and complete as possible and must not be misleading.
2.
We may take reasonable steps and actions to ensure the accuracy and currency of your Information.
3.
If you wish to correct, update, change, and/or add to your Information on the Rey Platform, please contact us in writing via the email address provided in the Contact Us section of this Privacy Policy.
4.
We are not responsible for any limitations, delays, failures, losses, or other issues related to your use of the Rey Platform and/or Services resulting from inaccuracies, omissions, and/or errors in the Information You provide to us.
H.
Your Rights
You have the following rights under the Indonesia's Personal Data Protection Law regarding your Personal Information:
1.
Right of Access.
You can request a copy of the Personal Information We hold about You. After We verify your identity, We will provide You with access to the requested Personal Information unless restricted by applicable laws or the rights and freedoms of others.
2.
Right to Rectification.
You may correct or complete inaccurate or incomplete data. We will promptly update your data upon receiving a valid request under our obligations under applicable laws.
3.
Right to be Forgotten
You have the right to request the deletion of your Personal Information under the following circumstances: (i) when the personal data is no longer necessary for the purposes for which it was collected or processed; (ii) if You withdraw consent on which processing is based, and there is no other legal basis for processing; (iii) if the Personal Information has been unlawfully processed; or (iv) if the deletion is required to comply with a legal obligation.
Notwithstanding the foregoing, We may retain certain Personal Information where necessary to comply with legal obligations, to protect the public interest, to resolve disputes, or to establish, exercise, or defend legal claims.
4.
Right to Restriction of Processing.
You have the right to request the restriction of processing of your Personal Information in specific situations, including but not limited to: (i) when You contest the accuracy of the Personal Information for a period enabling us to verify its accuracy; (ii) if the processing is unlawful, and You oppose deletion and instead request restriction of use; (iii) when We no longer need the Personal Information for processing purposes, but You require it for the establishment, exercise, or defense of legal claims; or (iv) if You have objected to processing, pending verification of whether our legitimate grounds override yours.
During the period of restriction, We will continue to store your Personal Information but will not process it except in certain circumstances, such as with your consent, for legal claims, to protect another person's rights, or for important public interest.
5.
Right to Data Portability.
You have the right to request a copy of your Personal Information in a structured, commonly used, and machine-readable format. You can also ask to transfer that Personal Information directly to another data controller if it is technically feasible. This right applies only to the Personal Information You provided, which We process based on your consent or for the fulfillment of a contract with You.
6.
Right to Withdraw Consent.
The processing of your Personal Information is based on your consent; You have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. Upon withdrawal, We stop processing your Personal Information for the purposes for which you initially consented unless there is another legal reason that permits us to continue processing it.
To exercise any of the rights mentioned above, please contact us using the information in the “Contact Us” section below. We will respond to your request in compliance with applicable data protection laws and may require You to verify your identity before We can process your request.
I.
Legal Basis for Processing Your Personal Information
In compliance with Indonesia's Personal Data Protection Law, We process your Personal Information based on the following legal grounds:
1.
Consent
Your Personal Information is processed only when You have provided specific consent.
2.
Contractual Obligations
Processing is necessary to fulfill our contractual obligations to You.
3.
Legal Obligations
Processing is required to comply with applicable legal and regulatory requirements.
4.
Legitimate Interests
Processing is necessary for our legitimate business interests, provided these do not override your rights and freedoms. This includes activities such as improving our services and ensuring security.
J.
Other Provisions
1.
The Rey Platform may contain links that connect You to other sites operated by third parties. In this case, You agree and understand that we are not responsible for managing personal information on those other sites. This Privacy Policy applies only to the Rey Platform and/or Services.
2.
These provisions are governed by Indonesian law and are made in both Indonesian and English versions. If there is any difference in understanding or interpretation, the Indonesian version will prevail.
3.
Any breach of Information protection or security that may occur from time to time and is not caused by Rey’s error and/or negligence. Rey has procedures and measures in place to ensure the Platform's security from malware or other issues. While these procedures are effective, Rey cannot guarantee that its protection or security system will not be breached and/or hacked by third parties. Rey will inform you as soon as possible in writing if a breach of protection or security of your Information occurs.
4.
You may request access to, obtain copies of, terminate processing, delete, and/or destroy your Information at any time by submitting a written notification to Rey through the contact details provided in the Contact Us section. However, you must be aware that such requests for withdrawal of consent, deletion, and/or destruction of your Information may result in your inability to use the Rey Platform and/or Services. You acknowledge and agree that by withdrawing your consent, we may not be able to provide our Services to You, and You agree to release us from any legal consequences, including claims, losses, or damages that may arise from the termination of such Services.
5.
We may modify this Privacy Policy at any time without prior notice or consent from you, as long as the changes to this Privacy Policy are permitted and/or required by applicable regulations (“Changes”). These changes are made to comply with applicable laws, improve services, add new features, enhance technology, and for other reasons deemed necessary to protect your and our interests. If we make Changes, they will be displayed on this page, and we will indicate the effective date of the updates at the bottom of this page.
Your continued use of our Platform and/or Services after any Changes constitutes your acceptance of the Changes, and you will be legally bound by the updated provisions. If You do not accept any Changes to this Privacy Policy, You must immediately stop using our Platform and/or Services.
K.
Contact Us
If you have any questions and/or complaints regarding this Privacy Policy or if you wish to request copies, delete, amend, and/or correct your Personal Information, please contact Rey in writing at:
PT Vertika Technologies Nusantara (Rey) Address: Sampoerna Strategic Square, South Tower 19th Floor, Jl. Jend. Sudirman Kav. 45 – 46, Jakarta 12930, Indonesia Email: [email protected] Phone/WhatsApp: +62 811-1499-739
Consumer Complaint Service Directorate General of Consumer Protection and Trade Order, Ministry of Trade of the Republic of Indonesia Phone/WhatsApp: +62 853-1111-1010
Data Protection Officer For inquiries related specifically to data protection, please contact our Data Protection Officer (DPO) at [email protected]
Effective Date These Privacy Policy were last updated and are effective as of January 12, 2023.
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