Personal data refers to any information, data and/or statements in any form that can identify you, which you provide to Us from time to time or which you include or submit in, on, and/or through the Platform concerning information about yourself (“Personal Data“). Please note that Personal Data here does not include any personal information that is already available in the public domain. Hularo processes your Personal Data in accordance with applicable privacy and data protection laws in the Republic of Indonesia.

Personal Data collected when you use the Platform, receive or provide Services, includes:

1) Personal Data collected from you as a Platform user is as follows:

1. Personal Data submitted by you voluntarily and independently, including but not limited to Personal Data submitted when you:
   1. Create or update your account, including but not limited to name, date of birth, mobile phone number, address, photo, and/or other information;
   2. Upload your personal data to the Platform;
   3. Contact Us, including but not limited to through the help page on Our Platform;
   4. Fill out surveys sent by Us or on Our behalf;
   5. Interact with Our social media;
   6. Use features that require permission to access your device; and/or
   7. Other data submitted through third-party services in connection with the use of the Platform.
2. Data recorded when you use the Platform, including but not limited to:
   1. Real or estimated location data, including but not limited to IP address, Wi-Fi location, geo-location, GPS coordinates, and other information provided by your device. You can enable or disable location recognition services when you use the Platform;
   2. Data in the form of your activities, including but not limited to registration activities, login, use of the Platform and so on;
   3. Platform usage or configuration data, including your interactions in using the Platform, saved choices, and selected settings. This data is obtained using, including but not limited to cookies, tag managers, and similar technologies that create and maintain unique identifiers;
   4. Device data, including the type of device used to access the Platform, including but not limited to hardware model, operating system and version, software, file name and version, language selection, unique device identifier, advertising identifier, serial number, device movement information, and/or cellular network information, and other additional data required by referring to the browser or application access request on your device;
   5. Log data, including records on the server that receives Personal Data such as the device’s 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 that you use before interacting with the Platform;
   6. Data obtained from camera access activities on your device, provided that you have obtained prior approval from you when the Platform is first used and such access is only for certain features or services on the Platform that must use a camera in order to use each Service to its full potential; and
   7. The Platform will ask you for permission to access the camera, gallery and documents when you upload documents in order to complete the filling in of health information. The Platform will not take or use any other information, data or documents other than those selected by you.

2) Personal Data collected from you as an Expert on the Platform is as follows:

1. Personal Data submitted by you voluntarily and independently or as requested by Us, including but not limited to Personal Data submitted when you create an account on the Platform.
2. Personal Data recorded when you use the Platform as set out above.

3) Operational data: To improve the experience of using the Platform, We may use cookies, server logs and other similar mechanisms to enable certain functions, improve the Services, monitor the use of the Services, and for marketing purposes on and off the Platform. These mechanisms are used to store user preferences, maintain session settings, assist in automatic authentication for frequently used Services when required by your settings, and enable other similar functional requirements. You may use your browser settings to disable cookies while using the Platform. However, this may prevent you from accessing all or part of the Platform, or from using all or part of the functionality within the Platform. Our third-party partners may also automatically receive and store non-personal information or anonymized data about your online activities over time.

We may use your Personal Data collected for the following purposes or for other purposes permitted by applicable laws and regulations:

1. To identify and register you as a user and to administer, verify, deactivate or manage your account on the Platform.
2. To respond to your submissions and fulfill your requests.
3. To send you administrative information, for example, information about the Platform.
4. To process and respond to questions, comments and feedback received from you.
5. To monitor and analyze your activities, behavior and demographic data as a user including your habits and use of the various Services available on the Platform.

We may also use your Personal Data more generally for the following purposes (although in certain cases We will act reasonably and not use your Personal Data more than what is necessary for the purpose):

1. to perform related service processes and functions.
2. to monitor the use of the Platform and to manage, support and improve the efficiency of the performance, development, user experience and functions of the Platform.
3. to provide assistance in connection with and to resolve technical difficulties or operational problems with the Platform or Services.
4. to generate statistical information and analytical data for the purpose of testing, research, analysis and development of the Platform.
5. to prevent, detect and investigate any prohibited, illegal, unauthorized or fraudulent activity.
6. to enable Us to comply with all obligations under applicable laws and regulations, including but not limited to responding to regulatory requests, inquiries or directives, complying with applicable regulatory filing, reporting and licensing requirements) and conducting audits, due diligence and investigations.

1. Cookies are small files that will automatically take place on your device that perform the function of storing your preferences or configurations while visiting a site. These cookies are not intended to be used when accessing other data that you have on your computer device, other than what you have agreed to submit.
2. Although your computer device will automatically accept cookies, you can choose to make modifications through your browser settings, namely by choosing to reject cookies (this option may hinder the optimal availability of the Service when you access the Platform).

Please note that when you use the Platform, there may be links to other platforms or websites owned by third parties including their content (“Third Party Platforms“) provided for your convenience. We are not responsible for the Personal Data management policies on such Third Party Platforms. This Privacy Policy is only intended and applies to Services through the Platform. We strongly recommend that you always view and carefully study the personal information management policies applicable to Third Party Platforms before providing your personal information.

In accordance with applicable laws and regulations, upon your request/application via the Contact Us page, We may delete (right to erasure) and/or destroy your Personal Data from the system (right to delisting) so that the data no longer identifies you, except in the case of:

1. If We need to store Personal Data to fulfill administrative, legal, audit, and/or accounting obligations, We will store the required Personal Data as long as you are still using the Platform or according to the period required by applicable laws and regulations.
2. Your Personal Data is still within the retention period based on applicable laws and regulations; and/or
3. for the purpose of destroying your Personal Data from the system (right to delisting), a court order is required by you so that We can destroy your irrelevant Personal Data from the system under Our management.
4. You understand that once your account is deleted, your account (including all transaction history and all services therein) will be deleted forever and cannot be restored for any reason.