Introduction
Thank you for accessing the telin.net website operated by Telekomunikasi Indonesia International (Hongkong) Limited (“Telin,” “we,” “our,” or “us”). We respect your privacy and want to protect your information. This Privacy Policy governs telin.net and tnex.telin.net websites and their subdomains (the “Sites”), Telin applications, products, services, events, and any interactive features and applications (the “Services”) that reference this Privacy Policy. References to “user”, “you”, or “your” are references to the visitors of the Sites. To the extent we provide you notice with different or additional privacy policies or practices (e.g., at the point of collection of your information), those additional terms shall govern such data collection and use. This Privacy Policy also applies to information we may collect from you while visiting our booth during an event, accessing a white paper online, via telephone calls with our office, through online payments, or in any other instance when you contact us. By using or interacting with our Sites, purchasing our products, or using our services, you acknowledge and confirm that you have read this Privacy Policy. If you are using the Services on behalf of a company, partnership, association, government or other organization (Your 'Organization'), you warrant that you are authorized to do so and that you are authorized to bind Your Organization to this Privacy Policy. In such circumstances, “user”, “you”, or “your” will include Your Organization.
This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties (“Third Party Services”), which are governed by their respective privacy policies. This Privacy Policy does not apply to any content processed, stored, or hosted by our customers using the Telin services. Telin is a processor of customer (“Customer”) content and processes such data at the direction of its controller of the Customers.
This Privacy Policy explains what personal information we collect from you, why we collect it, under what circumstances we may share it with third parties, how we protect your personal information, and your privacy rights. Personal information means any information relating to a natural person whether identified or capable of being identified independently or in combination with other information, whether directly or indirectly, through the use of an electronic system and/or non-electronic means.
In addition, please review the Sites’ Terms of Use, which govern your use of the Sites.
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What Information We Collect
We collect personal information from you in a variety of ways when you interact with our salespersons, Sites, and/or mobile services. Below is a list of personal information that we collect and the sources from which we collect the information.
(a) Information You Provide to Us
In connection with the products and services we provide, we may ask you to provide us with the following categories of personal information. Not all categories may be collected about every individual:
• Personal identifiers (e.g. name, mailing address, email address, phone number)
• Characteristics of protected classifications (e.g. gender, age, nationality)
• Commercial information (e.g. products or services purchased, purchase history)
• Internet or other electronic network activity (e.g. browser, cookie ID or search history)
• Audio, electronic, visual, or similar information (e.g. recording of guest service calls)
• Geolocation data (e.g. latitude or longitude)
• Financial information (e.g. credit or debit card numbers, bank account numbers)
• Education information (e.g. degree and schooling information)
• Professional or employment information (e.g. industry, occupation, title)
(b) Information We Collect When You Use the Sites
In addition to information that you choose to submit to us, we and our service providers automatically collect and store certain information when you visit or interact with the Sites (“Usage Information”). This Usage Information may be stored or accessed from your personal computer, laptop, tablet, mobile phone or other device whenever you visit or interact with our Sites. Usage Information may include:
• Your IP address, UDID or other unique identifier
• Your device functionality, including browser, operating system, hardware, and mobile network information
• Internet, application, and network activity, such as cookie IDs and browser visits
• Location information, such as geo-location information
(c) Information Shared to Us by Third Parties
We may collect your personal information from third parties (including our partners, service providers, agents, vendors, and any other parties providing services to us that collect and process your personal information on our behalf, or whom we cooperate with). In these cases, we will only collect and process your personal information in accordance with the purposes for which they are engaged, or the purposes of our cooperation with them (as applicable).
Why We Collect Information
We collect your personal information to provide you with our products and services, such as to fulfill your requests for services or to help us personalize our services and marketing to you. We also collect your personal information to support our business functions, such as customer service, recruiting, and legal functions. Below are some ways in which we use your personal information:
• Registering and maintaining your account
• Processing your order(s) and providing you with customer service, including responding to your inquiries regarding our products and services and/or communicating with you regarding orders, purchases, and payments
• Complying with legal obligations, including, complying with a request for data based on a lawful request from the authority
• Sending you marketing information about Telin and our affiliates
• Sending you email communications such as electronic newsletters about our products, services, events, and promotions
• Improving the effectiveness of our Sites, marketing endeavors, and product and service offerings
• Identifying your product and service preferences, providing personalized content and ads and informing you of new or additional information, products and services that may be of interest to you
• Allowing you to participate in interactive discussions and public forums
• Helping us address problems with and improve our Sites and our products and services
• Protecting the security and integrity of the Sites
• For other internal business purposes, and
• For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy
How We Share Information
We may need to disclose your personal information to Telin affiliated companies, service providers, and third parties in order to provide products and/or services to you. We do not sell your personal information to third parties for money.
Examples of when Telin shares your personal information include:
(a) Third Parties Providing Services to Telin. We may use third party service providers to perform certain services on behalf of us or the Sites, such as: (i) delivering our Services; (ii) processing credit cards and/or electronic payments; (iii) assisting us in Sites operations; (iv) managing a database of customer information; (v) hosting the Sites; (vi) designing and/or operating the Sites’ features; (vii) tracking the Sites’ activities and analytics; (viii) enabling us to send you special offers or perform other administrative services; and (ix) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information to carry out the services they are performing for you or for us. We require our service providers to keep user information secure. We do not allow our service providers to use or share user information for any purpose other than providing services on our behalf.
(b) To Protect the Rights of Telin and Others. To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Telin or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, search warrant, subpoenas, or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.
(c) Affiliates and Business Transfer. We may share your information with our subsidiaries and affiliates. As part of this sharing of information with our subsidiaries and affiliates, this means that once you provide us with information, any one of our related entities may use your information, including for marketing purposes, pursuant to the terms of this Privacy Policy. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Sites and/or our services; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during any due diligence process.
Cookies
Our Sites use cookies, pixel tags, log files, web beacons, and similar tracking technologies from third parties (collectively, "cookies"). These mechanisms indirectly or passively collect certain information about your use and interaction with our Sites and when you use our services. Those cookies help us serve you better by understanding what you’re interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. For more information about how we use cookies and your choices, please refer to our Cookies Policy in Section B below.
Location of Your Information
Telin is located in Indonesia, and our affiliated companies are located throughout the world. Depending on the scope of your interactions with our services, your personal information may be stored in or accessed from multiple countries, including Hong Kong and Indonesia. Whenever we transfer personal information to other jurisdictions, Telin will use its best endeavors to ensure that the information is transferred in accordance with this Privacy Policy and as permitted under applicable data protection laws.
Data Security
Telin is concerned with the security of the data we have collected and utilizes reasonable measures to prevent unauthorized access to that information. These measures include policies, procedures, employee training, physical access, and technical elements relating to data access controls. In addition, Telin uses standard security protocols and mechanisms to facilitate the exchange and transmission of sensitive data, such as credit card information, and has procedures in place to deal with any data breach. We will notify you and any applicable regulator of a data breach where we are legally required to do so.
Please note that while we incorporate commercially reasonable safeguards to help protect and secure your personal information, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, Telin cannot guarantee or warrant the security of any information you transmit to or from our Sites, and you provide us with your information at your own risk. If you must transmit confidential information to us for any reason, please contact us for instructions for a secure file transfer protocol.
Your Marketing Choices
We may send you direct marketing messages including by way of email alerts. By agreeing to this Privacy Policy, you agree to be part of TNeX’s mailing list whereas you may receive our email marketing or general information communications. You can opt-out of such communications at any time by clicking on the unsubscribe link in the relevant communication or contacting us at marketing@telin.net.
Telin as a Data Processor for TNeX’s Customers
When providing infrastructure as a service (IaaS), Telin may process information controlled by its customers located in various jurisdiction, which may include personal data (“Customer Content”). Telin’s customers are the data controllers of personal data within the Customer Content and are responsible for compliance with the applicable data protection laws of their jurisdictions, such as Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (“Hong Kong PDPO”) and Law of Republic Indonesia No. 27 of 2022 on Personal Data Protection ("Indonesian PDP Law”). Telin processes Customer Content as a data processor at the direction of its customers in accordance with the terms of this Privacy Policy.
The provision of IaaS may, at the direction of the customer, include the transfer of customers’ and/or its end users’ personal data outside of their jurisdictions which may not provide the same level of data protection as in their jurisdiction. The customer is responsible for ensuring that it has (i) complied with the requirements of international transfers of personal data under the applicable laws, and (ii) obtained all necessary disclosures and consents in place with data subjects for international transfers of personal data, that it directs as part of its receipt of IaaS.
Telin may engage with third-party service providers and/or its affiliated companies outside of its customer’s jurisdiction in providing services. Telin shall give its best effort to ensure that all personal data is handled, processed, transferred and stored in accordance with Hong Kong PDPO and Indonesian PDP Law, and relevant applicable personal data protection laws and its derivatives and amendments, and that adequate safeguards and procedures providing protection to customer personal data are in place.
On occasion, employees of Telin may have temporary access to Customer Content in connection with providing maintenance or support services to you. This access will only be accomplished by way of your explicit permission and instructions (as the controller of the customer content) and only for so long as the employee is providing services to you. As a processor related to Customer Content, Telin will not access the Customer Content for any purpose beyond providing you with support as described above and will not disclose it to any person or entity.
Your Privacy Rights
As a customer of TNeX, you may have the following privacy rights:
• Access. You have the right to obtain access to and request a copy of the personal information that we are processing about you.
• Rectification. You have the right to complete, update, and/or correct any mistake in your personal information, whether incomplete or inaccurate, that we hold about you.
• Deletion and destruction. You have the right to terminate processing, erase, and/or destroy personal information concerning you in certain situations, such as where we no longer need it or if you withdraw your consent (where applicable).
• Objection. You have the right to (i) object at any time to any decision-making based solely on automated processing of your personal information, including profiling or direct marketing purposes and (ii) object to our processing of your personal information where the legal ground of such processing is necessary for legitimate interests pursued by us or by a third party. We will then abide by your request unless we can demonstrate compelling legal grounds for the processing.
• Restriction. You have the right to request that we suspend and/or restrict our processing of your personal information in certain circumstances, such as when you contest the accuracy of that personal information, for the period in which we have to verify the accuracy of the personal information.
• Portability. You have the right to receive the personal information concerning you that you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit that data to a third party in certain situations.
• Withdrawal of consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
• You also have the right to lodge a complaint before your national data protection authority.
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process your personal information or where data may be exempt from disclosure due to professional secrecy obligations.
If you would like to exercise any of these rights, please:
• Submit a request by using our Personal Data Subject Rights Form.
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• Email us at tnexprivacy@telin.net
• Provide enough information to identify yourself (e.g., name, email address, etc.)
• Provide proof of your identity and address (e.g. a copy of your driver’s license or passport and a recent utility or credit card bill) and
• Provide the information to which your request relates
Privacy of Children Online
Our Sites and Services are not directed to children under the age of 21 and do not knowingly collect personal information from children under the age of 21. If you are under the age of 21, please do not use our Sites or Services or otherwise provide us with any personal information. Please contact us at tnexprivacy@telin.net if you have concerns regarding the potential collection of your child’s information. If we learn that any personal information we collect has been provided by a child under the age of 21, we will promptly delete that information.
Updating Personal Information
We strive to keep your personal information accurate and up to date. If you would like to update your personal information, you can accomplish it in the following ways:
• If you have created an account on our Sites, log into your account. Once you do, you will be able to enter and update your own contact information.
• Contact us at tnexprivacy@telin.net. We will use good faith efforts to make requested changes in our then active databases as soon as reasonably practicable(but we may retain prior information as business records, to the extent permitted under the laws and regulations). Please note that it is not always possible to completely remove or delete all your information from our databases and that residual data may remain on backup media or for other reasons, such as a legitimate business reason.
Do Not Track Disclosures (DNT)
Various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that relies on a technology known as a DNT header that sends a signal to websites visited by the browser user about the user's DNT preference. You can usually access your browser's DNT option in your browser's preferences. Telin currently does not respond to DNT signals in browsers because no DNT standard has been adopted by the industry.
Links to Other Websites
For your convenience, the Sites may contain links to other websites. Telin is not responsible for the privacy practices, advertising, products, services, or the contents of such other websites. None of the links on the Sites should be deemed to imply that Telin endorses or has any affiliation with the links.
Information Retention
We will retain your personal information for as long as necessary for the purposes for which that information was collected as set out in this Privacy Policy or for longer as required under any applicable legal, regulatory, accounting, or reporting requirements. Should you opt out or no longer wish to receive marketing messages from us, we will securely delete your personal information from the relevant mailing list(s).
Contacting Telin
If you have questions or concerns with respect to our Cookies Policy, you can contract uas at:
Attn:
Telekomunikasi Indonesia International (Hongkong) Limited
Product & Innovation Development
C.q Legal & Compliance Unit
E-mail: tnexprivacy@telin.net with a copy to pid@telin.net and legal@telin.net
Changes in Privacy Policy
We may make changes to this Privacy Policy from time to time. If there are any significant, material changes to this Privacy Policy, we will publish a notice on the Sites and notify you through pop-up notice within the Sites, and may request for your consent (as necessary). Please check our Privacy Policy periodically for changes. All the changes will become effective on the date last updated. If you are concerned about how your personal information is handled, please visit our Sites often for this and other important announcements and updates.