Privacy Policy

PT Next Innovation Indonesia provide services under the brand name “Smaluna” (hereinafter “Smaluna” or “We”) that allow you to earn rewards from, including but not limited to, answering health questionnaires, reading health articles and taking part in activities in the application so you can help yourself to better manage your own health, enrich your life and obtain benefits from future services which may be available to you. Rewards are the discounts, cash rebates, other cash rewards, points and/or other rewards that we offer you as a Registered User.

To provide you with Smaluna’s services, we collect information about you. As described below, we are able to offer its services to you for free through the development and marketing of anonymous consumer data and advertisements. We recognize that you should have the right to know how the data we collect and/or are provided with are used, processed, analyzed and disclosed, and what controls you have over that data once shared with us.

This Privacy Policy applies to all information Smaluna and any corporate affiliates collect and/or are provided with for current and former consumers in connection with all the products, services, websites, microsites and mobile applications we offer on behalf of ourselves or others, and constitutes our internal policy in protecting Personal Information as required by applicable laws and in force in Indonesia

Please read this Privacy Policy carefully and contact us if you have any questions or concerns. You may rest assured that we take privacy and security seriously and are receptive to any feedback on these issues. If you have any queries, comments, or concerns, or otherwise require any help, please feel free to contact us at info@smaluna.id.

By ticking the consent box available on our mobile application and/or using our products or services, we assume that you have carefully read and agreed to our Privacy Policy, and verified, confirmed and consented to the accuracy, confidentiality and purpose of use of Personal Information about you and how the Personal and/or Non-Personal Information we collect and/or are provided with are used, processed, analyzed and disclosed.

In this privacy policy we describe the information we collect and how we use and share it. By using Smaluna’s websites, mobile apps, or services that facilitate the provision of such websites and mobiles apps (“Services”), and accepting the Terms of Service, you agree to this Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT USE THE SERVICES.

Unless defined otherwise in this Privacy Policy, all terms defined in this Privacy Policy have the same meanings given to them in our terms of services (“Terms of Services”). This Privacy Policy is an integrated, inseparable part of the Terms of Services.

We will never transfer personal data to third parties except the trusted partner(s) who work(s) with us under strict confidentiality agreements in order to de-identify data (remove any identifiable information). Our business model is based on the creation of predictive models using statistics and machine learning techniques relating to the information you provide to us.

To produce these models, we anonymize and aggregate data we collect from you. These models do not represent user profiling in any way, and they do not allow for any proxies regarding a specific user of our services.

Scope of Privacy Policy
This Privacy Policy applies to all data and information collected by Smaluna. We consider personal information to be information that can be used to determine the actual identity of a specific individual and to contact that person, such as name, address, email address, and/or phone number. We do not consider personal information to include information that, taken alone, does not allow a third party to easily identify and contact a specific individual.

Highlights of what you are consenting to:

By using the Services, you are consenting to:

1. The collection, use, store and processing of all the information you provided in our application such as answering health and financial questionnaires;

2. The collection, use, store and processing of information collected from the online accounts you connect to the Service, such as email receipts;

3. The use of cookies and related technology;

4. The sharing of personal information with the trusted partner(s) who work(s) with us under strict confidentiality agreements in order to turn personal information to anonymous transaction information;

5. The sharing of aggregated and anonymized data in relation to the information you provide to us, with service providers and vendors;

6. The collection, use, sharing and other processing of your information as otherwise described in this Privacy Policy.

What information does Smaluna collect and/or provided with?

We may collect and/or are provided with the following types of information:

Information you provide

The personal and/or non-personal information that we receive is only limited to what is provided by users; such as, but not limited to; during the app’s sign-up process, users’ answers to questionnaires, etc. We will not collect any personal data without users’ consent. Every personal information we have are the information our users willingly and knowingly share.

Information Collected by Automated Means

We may obtain certain personal and non-personal information by automated means when you avail our Services. The type of information we collect by automated means may vary, but generally includes technical information about your computer, such as IP address or other device identifier. The information we collect also may include usage information and statistics about your interaction with our websites. That information may include the URLs of our web pages that users visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, and other information about how you used our websites.

In cases where you use our mobile application and give us permission, we will collect information about your precise location (latitude and longitude) through various means, depending on the service and device used, including Global Positioning System (GPS), Bluetooth and Wifi connections. In some cases, even if you are not using a mobile device, information about your general location may be discernable from your device’s IP address or the URLs we receive. If you access or use our sites or services with your mobile telephone, we may collect your telephone number.

Please note that if ads or other features on our site are provided by third parties, those parties also may use automated means of data collection that are subject to those third parties’ privacy notices and policies.

We use information we collect by automated means to understand our users and to determine their preferences. As a result, we can develop and deliver new or modified offerings, improved with our users’ preferences in mind. As described below, we also may use it to provide a more personalized user experience and to manage advertising.

Information from cookies

When you visit a Smaluna’s website and/or mobile application or click on a banner advertisement, we may send one or more cookies to your computer or any other device.

You can set your browser to refuse all cookies, delete previously stored cookies or to indicate when a cookie is being sent. However, some features or services of Smaluna website and/or mobile application may not function properly without cookies.

Email and Other Accounts

You may also provide information such as the login credentials for your email, social networking, or other Internet accounts that you consciously link to the Services. By linking the Services to your email or other Internet accounts, you authorize us to gather, parse, and retain information relating User ID of such external services and the information that you allowed the external service provider to share under the privacy settings.
We use the information collected from your email to provide you with our products and services, to improve these services, to conduct market research, and to produce and maintain aggregate statistics and provide market data services.

Log and other information
When a Smaluna website, mobile application, email, advertisement or other content served by or on behalf of us on other websites, microsites or mobile applications is accessed, we automatically record Personal and/or Non-personal Information about you that your browser and/or mobile application sends.

These logs typically include your web request, internet protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser, mobile application or Account(s) to us.

Other actions, such as interactions with advertisements, may also be included in our logs. During your visits to our website, microsites or mobile application, we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

Surveys

The Smaluna mobile application and/or Smaluna web site may request permission to send you emails containing links to surveys in which you will be involved, and may also be presented with surveys within the application and/or web site itself. Once you are in these surverys, your answers will be collected to the surveys and reused, by way of, among other ways, being processed, analyzed, stored, displayed, announced, sent and/or disclosed, and/or opening access to them.

Google/Facebook Login

The Smaluna mobile application may request your mobile application permission to link with your Google account, if you use Google Login to access the application.

If you grant the mobile application permission to access your Google account, Personal and/or Non-Personal Information from your Google profile will be collected.

We may also provide you the ability to log into our website using sign-in services such as Google or Facebook Login. These services will authenticate your identity and provide you the option to share certain Personal and/or Non-Personal Information with us such as your name and email address to pre-populate our sign-up form.

Services like Facebook Login give you the option to post Personal and/or Non-Personal Information about your activities on our website(s) to your Facebook profile page to share with others within your network.

Mobile Device Information

Smaluna may use tools, including third party analytical software, to automatically collect certain anonymous data about your device that does not directly identify you, such as: (i) device properties, including, but not limited to unique or other device identifier; (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) geographical data such as country or region; (v) other similar data as reasonably required by us to enhance the Services and other Smaluna products and services.

Geolocation Information

Every time you open the mobile application, you are asked to grant permission to access your geolocation information. If you give us permission, you will share your current location with us. Location information allows us to personalize and improve our services and advertising content. When the mobile application is not in use, the collection of geolocation information is disabled.

How does Smaluna use my information?

To manage your Account(s)

We use, process and/or analyze Personal and/or Non-Personal Information about you that we collect and/or are provided with to manage your Account(s).

For example, we use Non-Personal Information you provide us and the purchase information we collect to track, process, post and fulfill Rewards you earn and to provide customer service.

In addition, we may use Non-Personal Information and purchase information about you to keep you updated of new features and product developments as well as to provide more relevant offers to you.

For report purposes

We use, process and/or analyze the Personal and/or Non-Personal Information we collect and/or are provided with to provide our Clients with anonymous marketing objective and strategy reports that may contain processed, populated (not raw, directly or indirectly identifying) data. Our Clients will not be able to identify our users in any way by using the data we provide to our Clients.

To develop, evaluate, improve and deliver our products and services

We use the Personal and/or Non-Personal Information we collect and/or are provided with to develop, evaluate, improve and deliver our product and services.

For example, if we learn from the information we collect and/or are provided with that certain retailers, certain gamification or certain Rewards scheme are valuable to Registered Users, we may offer more services or Rewards for those products.

Fulfill legal and regulatory requirements

We will not use and process your Personal Information unless required to comply with federal, state, or other applicable laws and regulations.

Protect the rights or property of Smaluna or our Registered Users

We also may use Personal and/or Non-Personal Information about you that we collect and/or provided with to the extent we believe it is necessary or appropriate to enforce or apply our rights under our agreements with Registered Users and/or to protect the rights, property or safety of Smaluna, our Registered Users and others.

How does Smaluna share information about you?

Anonymized Personal Information

We anonymized the data contained in the information you provide to us to then proceed to analyze the data along with other users. We share and monetize these anonymized data to our third-party clients that work with us under strict confidential agreement. The data we share to our third-party clients can not be used to identify specific individual users.

Contests, sweepstakes and surveys

We may promote or offer contests, sweepstakes, similar promotional offers or surveys that may be co-sponsored by Smaluna and one or more other companies, or may be sponsored by anyone other than Smaluna. It is up to you if you want to join these contests or not.

Some or all the Personal and/or Non-Personal Information collected and/or provided with through these offers or surveys may be shared with the sponsor(s), Clients or other companies indicated on the entry form, in the governing rules or on the survey, as applicable. Your participation in such offers indicates your acceptance of such terms.

We may also use and disclose personal information and/or data for purposes of announcing winners and beneficiaries of these contests and promotions.

Third-party companies
We may share anonymized and aggregated data that we collect and/or with which we are provided with third-party market research and other unaffiliated companies who may use, process and/or analyze the anonymized and aggregated data for any legally permissible purpose including but not limited to matching to additional data sets, data analysis and research reports.

Information we share with nonaffiliated third parties as permitted by law

We reserve the right to disclose Personal and/or Non-personal Information about you to the extent permitted by applicable law, for example:

Business transfers

If there is a change of ownership in Smaluna’s business (whether by merger, sale of assets or otherwise), Personal and/or Non-Personal Information about you could be included as part of that transaction and could be used by the relevant counterparts.

Protection of Smaluna and others

We may display, announce, transmit, publicize and/or give access to Personal and/or Non-Personal Information about you to third parties when we believe such action is appropriate to comply with a legal requirement, such as a law, regulation, court order, subpoena or search warrant, or in the course of a legal proceeding.

We may also display, announce, transmit, publicize and/or give access to Personal and/or Non-Personal Information about you as we believe appropriate to enforce or apply our rights under our agreements with Registered Users, and to protect the rights, property or safety of Smaluna, our Registered Users and others, including exchanging information for fraud protection and credit risk reduction.

With your consent

In addition to the above, we may display, announce, transmit, publicize and/or give access to Personal and/or Non-Personal Information about you with others for purposes other than those set out elsewhere in this Privacy Policy, to the extent you consent to such action.

Non-Personal Information

We may provide aggregated Non-Personal Information about you to Clients, Partners or others for marketing, analysis and other purposes. For example, your purchase information may be aggregated with the purchase information of other Registered Users and analyzed to evaluate the effectiveness of certain award offers or advertisements, and the results of that analysis may be shared with Clients, Partners or others.

Security of Personal Information about You

Smaluna is committed to earning and keeping your trust. We understand the need for Personal Information about you to remain secure and private, and we have implemented security practices and procedures designed to safeguard Personal Information about you based on this Privacy Policy.

Only Smaluna employees and service providers who need to use, process and/or analyze Personal Information about you as part of their jobs are authorized to have access to Personal Information about you. Please remember that you also play a valuable part in data security. You should never share your Account password, if applicable, with anyone.

If you feel your password has been compromised, you should change it immediately. After you have finished using our mobile application or website(s), you should log out of your Account and exit your browser so that no unauthorized persons can use our website under your name or Account.

Account Deletion

In any case that you wish to have your account & data deleted from Smaluna because you will no longer use the app (or for any other reason), you can request for account deletion by contacting our customer service to do so. Once deleted, you will no longer be able to sign in using that account, neither can it be reactivated. Smaluna may need 14-21 working days to complete the account deletion request.

Online Forums

Please note that any Personal and/or Non-personal Information you voluntarily include in bulletin boards, chat rooms and other online forums we may offer may be viewed and used by anyone with access to those forums. Smaluna is unable to control any use of such Personal and/or Non-Personal Information.

Collection of Information from Children

None of our products or services is intended for use and/or purchase by children, unless such use and/or purchase is done with a consent from one of the biological parents or legal guardian of the relevant child using the products or services. If you are under the age of 18 or such younger age than the eligibility threshold to be deemed as an adult applicable in your jurisdiction, by ticking the consent box available on our mobile application and/or using our products or services, we assume that you have obtained a consent from one of your biological parents or legal guardian to use the mobile application and/or the products or services.

Changes to this Privacy Policy

Please note Smaluna reserves the right to modify and/or update this Privacy Policy from time to time so please review it frequently. We will post any Privacy Policy changes on this page and, we will provide a notice on the Smaluna mobile application or by email to the email address we have on file in your Account.

Each later version of this Privacy Policy will override the previous version, and we will also store previous versions of this Privacy Policy that you may review upon your written request to us.

How to Contact Us

If you have any queries about our Privacy Policy, you may contact us at info@smaluna.id. We will seek to attend to your request as best as we reasonably can.