Last updated: Sept 13, 2024

This privacy policy regulates how Lippo Karawaci, Tbk., affiliate and/or all of its subsidiaries ("Lippo Land") process your personal data and your rights as subject data.

 

I.          LAWFUL BASIS

Lippo Land may process your personal data if one of the following applies:

a.         You have given a consent by clicking the consent sign at the consent box;

b.         Providing personal data is necessary for the implementation of agreement between you and the Lippo Land;

c.         Processing is necessary to fulfil legal obligations that the Lippo Land must fulfil;

d.         Processing is related to tasks carried out in the public interest or the exercise of official authority granted to you; or

e.         Processing is necessary for legitimate interests pursued by the Lippo Land or third parties.

 

II.         PURPOSE

We process personal data covered by this privacy policy for the following purposes:

a.         account registration on LEAP, customer service, transactional interests including but not limited to book a unit, house loan application, payment, and/or charges information;

b.         make improvements to our services and products to ensure that the content presented is appropriate and efficient for you;

c.         generate statistical and research data for internal reporting and/or record keeping requirements;

d.         to initiate and maintain correspondence with you via electronic mail (email), SMS (short message service), registered mail, telephone calls and other channels;

e.         to control and prevent potential fraud against you and against us during the purchase process. If we determine that the transaction is potentially fraudulent, this processing may terminate the transaction;

f.          to send marketing communications, advertisements, vouchers, surveys, and information directly or targeted, and information about special offers or promotions and when events, promotions, features, or launches occur; and

g.         to perform contractual obligation, legal and/or regulatory compliance including compliance with legal or regulatory requirements.

 

III.        COLLECTED DATA

1.         We collect your personal data in various forms while you, among others:

 

a.         directly submit your personal data, for example, when you use, register, submit a question through LEAP or another our electronic system or provided by third parties;

b.         other information resources such as referral program, our business partner, public information, as emergency contact, financial institution, or government institution.

2.         Among the types of personal data, document, and personal information ("Personal Data"), either directly by Lippo Land or through third parties, are:

a.         Identities such as full name, family data, phone number, email, religion, marital status, bank account, debit or credit card number, home or work address, emergency contacts, and other supporting personal data;

b.         Documents that include Personal Data such as Affirmation and Approval of Unit Orders (PPPU), Purchase and Sale Binding Agreement (PPJB) documents, Sale and Purchase Deed (AJB), certificates of land and/or buildings, certificates of ownership of flats, rental documents, and other documents related to Property such as power of attorney from the Owner, Property Unit guarantee documents at banks or other third parties, and other relevant documents on the Property;

c.         Real or approximate location data such as IP address, WI-FI location, geo-location, and so on;

d.         Data in the form of time from each User activity, including registration, login, transaction activities, and so on;

e.         Data on the use of the LEAP by the User, including the User's interaction in using the LEAP, saved choices, selected settings, which are obtained using cookies, pixel tags, and similar technologies that create and maintain unique identifiers;

f.          Detailed transaction data, including the type, amount, and/or description of the services requested or used in the LEAP, the payment channel used, the payment amount, the date and time of payment, and other payment details, if the LEAP feature allows such a process;

g.         Device data, including the type of device used to access the LEAP, including hardware model, operating system and version, software, file name and version, language preference, unique device identifier, advertising identifier, serial number, device movement information, and/or mobile network information;

h.         Mobile terminal identifiers, location information, EP membership number, access information to the LEAP, and other information based on the User's use of the LEAP; and/or

i.          Log data, including records on the server that receives data such as the IP address of the device, the date and time of access, the features of the application or the duration viewed, the work process of the LEAP and other system activities, the type of browser, and/or the third-party application or service that the User uses before using the LEAP.

 

IV.        THE PERIOD OF DATA PROCESSING

1.         We process your Personal Data as long as you give consent and as necessary to fulfill the purposes of its submission and collection, or as required by applicable laws and regulations.

The Lippo Land may be permitted to process Personal Data for a more extended period whenever the User has given consent to such processing, as long as such consent is not withdrawn. In addition, the Lippo Land may be obliged to retain Personal Data for a more extended period whenever requested to do so for the performance of legal obligations or upon order of an authority.

 

V.         DATA STORAGE AND PROCESSING

1.         The Lippo Land takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. While we have used our best efforts to secure and protect your Personal Data, please note that data transmission over the Internet is never completely secure. As such, we cannot guarantee 100% security of the data provided or transmitted to us by the User and the provision of information by the User is at the User's own risk.

2.         Data processing is carried out using computers and/or supporting tools, following procedures and organizational modes closely related to the indicated objectives. Apart from the Lippo Land, in some cases, Personal Data may be accessed by certain types of persons in charge (administration, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting provider, IT company, communications agency) appointed, if necessary, as data processor by the Lippo Land.

3.         Lippo Land will only share your Personal Data with those who have a legitimate business need for it, competent law enforcement bodies, regulators, government agencies, courts, or other third parties where disclosure is required due to applicable laws or regulations. Whenever we permit a third party to access your Personal Data, we will ensure the Personal Data is used in a manner consistent with this privacy notice. Your Personal Data may be shared with our subsidiaries and affiliates and other third parties, including service providers.

 

VI.        RETENTION PERIOD

1.         Personal Data will be stored for as long as required by the purposes for which it was collected and/or for as long as such storage is necessary or permitted under the applicable laws and regulations.

2.         Once the retention period ends, Personal Data will be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the retention period ends.

 

VII.       YOUR RIGHT AND OBLIGATION

1.         You have the rights as a personal data subject to access, erase, rectify, and other rights as stipulated in Law No. 27 of 2022 on Personal Data Protection.

2.         You are responsible to ensure the accuracy of your Personal Data and shall inform us to rectify, complete, and/or renew your Personal Data. In the event there is any inaccuracy to your Personal Data, we reserve our right to terminate your usage on one of our electronic system. To apply for the exercise of one of the above rights, you may contact us as specified in the Terms and Conditions.

 

VIII.      MISCELLANEOUS

1.         We may revise this privacy policy from time to time.

2.         The revised privacy policy shall apply from the date of publication, and you hereby waive any right you may otherwise have to be notified of, or to consent to, revisions of this privacy policy.

3.         You hereby agree that we may assign, transfer, sub-contract or otherwise deal with our rights and/or obligations under this privacy policy.

4.         If a provision of these privacy policy is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect.

5.         If any unlawful and/or unenforceable provision of this privacy policy would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.

6.         A provision under this privacy policy is for our benefit and your benefit and is not intended to benefit or be enforceable by any third party.

7.         The exercise of the parties’ rights under a contract under this privacy policy is not subject to the consent of any third party.

8.         Our privacy policy shall constitute the entire agreement on data processing between you and us and as long as there in no conflicting provision, these shall supersede all previous agreements between you and us in relation to your Personal Data.

9.         Any disputes relating to this privacy policy shall be subject to the laws of Republic of Indonesia and exclusive jurisdiction of the District Courts of Tangerang.