Privacy Policy

A. Introduction

PT Solih Penuh Rizki (hereinafter referred to as the "Company" or "SPR" or "We") understands the importance of protecting the personal data of each of Our customers. Therefore, We are committed to protecting and safeguarding the personal data of identified or identifiable individuals, whether separately or in combination with other information, either directly or indirectly through electronic or non-electronic systems ("Personal Data"), in accordance with Law No. 27 of 2022 on Personal Data Protection and its applicable implementing regulations.

This Privacy Notice explains how We collect, use, disclose, store, share, distribute, process, and delete ("Personal Data Processing") Personal Data and/or cooperate or have legal relationships with third parties ("Third Parties") to carry out Personal Data Processing in connection with the products, services, activities, and other features that We provide and offer directly or through media such as websites, applications, and/or systems (if any) ("Products and/or Services").

This Privacy Notice applies to any Personal Data Processing carried out by Us when You:

• access and/or use Our media such as websites, applications, and/or systems;
• become a prospective user or user of Our Products and/or Services; and/or
• become (i) Our partner, contractor, and/or supplier, and/or (ii) have a legal relationship with Us for a specific purpose, such as the implementation of corporate social and environmental responsibility (CSR),

(collectively hereinafter referred to as "You"), whether through this website, other websites, applications operated or provided by Us, or Personal Data Processing carried out at exhibitions or by other means in the provision of Our Products and/or Services.

B. Statements and Warranties from You Regarding the Provision of Personal Data

By using Our website or application, Our Products and/or Services, or by providing Your Personal Data to Us or to Third Parties appointed by Us, either directly or through Your lawful representative, You represent and warrant that:

• You have read and fully understood this Privacy Notice and understand the Personal Data Processing carried out by Us; and
• All Personal Data You provide is genuine, complete, and accurate.

C. Types of Personal Data Collected and How We Obtain Them

The Personal Data We collect includes general and specific Personal Data, including but not limited to:

For certain purposes, You may be required to provide Personal Data in order to comply with legal obligations or to perform an agreement. Failure to provide such Personal Data may be considered a failure to fulfill legal obligations or an inability to enter into an agreement with Us.

We may collect information from various sources in accordance with applicable laws and regulations, including Personal Data collected by Third Parties and/or public sources, whether new or historical data, in order to continuously provide the best Products and/or Services to You.

We may obtain and collect Your Personal Data through various activities and means, including:

• when You access websites, applications, or other platforms provided by Us;
• when You or Your lawful representative attend events organized by Us, either online or offline (including promotional programs);
• when You conduct transactions with Us through available means;
• when You visit Our branches or offices;
• through Third Parties.

D. Purposes of Personal Data Processing

We process Your Personal Data for purposes including but not limited to:

• Providing Our Products and/or Services (including responding to inquiries, comments, or complaints)
• Detecting, preventing, and resolving issues related to Our Products and/or Services
• Managing daily business operations and internal administrative processes, including documentation, audits, and taxation
• Fulfilling obligations under agreements with You and/or Third Parties, including notifying You of changes to Products and/or Services
• Communicating with You via various media such as email, telephone, SMS, in-app messaging/push notifications, and social media
• Verifying Your identity
• Offering, marketing, and promoting Our Products and/or Services and those of SPR Companies
• Processing Your participation in events, contests, games, promotions, polls, or surveys
• Analyzing usage and sales patterns for research, analysis, testing, and development
• Preventing, detecting, and investigating suspicious transactions, criminal acts, or prohibited activities
• Complying with law enforcement requests and protecting Our and/or Your rights
• Developing and improving Products and/or Services; and/or
• Fulfilling other necessary purposes

E. Legal Basis for Personal Data Processing

Personal Data Processing is carried out based on:

F. Personal Data Processing by Third Parties

We may disclose Personal Data to SPR Companies and Third Parties as necessary for the purposes stated in this Privacy Notice, including:

• Research companies
• IT service providers
• Payment processors
• Professional advisors (legal, accounting, auditing)
• Government authorities and regulatory bodies
• Parties involved in corporate transactions (mergers, acquisitions, restructuring)
• Other third parties with Your consent or as required by law

G. Personal Data Retention

We retain Personal Data as long as necessary to fulfill processing purposes, comply with legal obligations, resolve disputes, and enforce agreements. Personal Data may be deleted when no longer required for the purposes for which it was collected, subject to applicable legal requirements.

The retention period depends on various factors including:

• The nature and sensitivity of the Personal Data
• Legal and regulatory requirements
• Business and operational needs
• The purposes for which the data was collected

H. Data Storage and Cross-Border Transfer

Your Personal Data may be transferred, stored, and processed outside Indonesia, subject to applicable laws and regulations. When Personal Data is transferred internationally, We ensure appropriate safeguards are in place to protect Your data in accordance with this Privacy Notice and applicable data protection laws.

Processing of Personal Data transferred outside Indonesia remains governed by this Privacy Notice and applicable Indonesian data protection regulations.

I. Rights of Personal Data Subjects

Under applicable data protection laws, You have the following rights regarding Your Personal Data:

Requests to exercise these rights may be submitted through the contact details provided below and are subject to identity verification for security purposes. We will respond to Your requests in accordance with applicable laws and within reasonable timeframes.

J. Personal Data Security

We take reasonable technical, organizational, and administrative measures to protect Personal Data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication mechanisms
• Regular security assessments and audits
• Employee training on data protection
• Incident response procedures

K. Amendments to the Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in Our practices, legal requirements, or for other operational, legal, or regulatory reasons. When We make material changes, We will notify You through:

• Posting the updated Privacy Notice on Our website
• Updating the "Last Updated" date at the top of this Privacy Notice
• Sending notifications through email or other communication channels (for significant changes)

Continued use of Our Products and/or Services after the effective date of the updated Privacy Notice constitutes Your acceptance of the changes. We encourage You to review this Privacy Notice periodically.

L. Contact Us

For further information, questions, concerns, or to exercise Your rights regarding this Privacy Notice or Our Personal Data Processing practices, please contact us at:

We will make reasonable efforts to respond to Your inquiries and requests in a timely manner.

M. Language

This Privacy Notice may be translated into languages other than Indonesian for Your convenience. In the event of any discrepancies or conflicts between different language versions, the Indonesian version shall prevail and govern to the extent permitted by applicable law.