Privacy Policy

PRIVACY POLICY

as of December 2024

The following Privacy Policy describes how we, RoRo (PT Aplikasi Tepat Guna, and its affiliates, “we”, “us” or “our”) collect, store, use, process, retain, transfer, disclose and protect your Personal Information. This Privacy Policy applies to all users of our applications, websites (https://www.prahu-hub.com/ and https:// https://roro.prahu-hub.com/user/login), services or products (“Applications”), except those covered by a separate privacy policy.

Please read this Privacy Policy in its entirety to ensure that you understand our data processing practices. Unless otherwise defined, all capitalized terms used in this Privacy Policy shall have the same meanings as given to them in the Terms of Use.

This Privacy Policy covers the following:

Personal Information we collect
Use of Personal Information we collect
Sharing Personal Information we collect
Storage of Personal Information
Access and correction of Personal Information
Where we store your Personal Information
Security of Your Personal Information
Changes to this Privacy Policy
Acknowledgement and consent
Marketing and promotional materials
Anonymous Data
Third party platforms
How to contact us

1. PERSONAL INFORMATION WE COLLECT

We collect information that identifies or can be used to identify, contact, or locate the person or device to whom such information pertains (“Personal Information”). Personal Information includes, but is not limited to, name, address, date of birth, occupation, telephone number, email address, bank and credit card account details, gender, identification (including national ID card, driver’s license, or passport) or other government-issued identifier, vehicle information, photograph, nationality, telephone numbers of our users and non-users in your mobile phone book, health data, financial information, and biometric information (including but not limited to facial recognition). In addition, to the extent that other information, including personal profiles, and/or unique identifiers, is associated or combined with Personal Information, then that information is also Personal Information. The Personal Information we collect may be provided by you directly or by third parties (for example: when you register for or use the Application, when you contact our customer service, or you otherwise provide Personal Information to us). We may collect information in a variety of forms and for various purposes (including purposes permitted by applicable law).

Information obtained from you or from your mobile device directly

When you register and create an account with us using the Application, you must provide us with certain Personal Information, including your name, physical address, email address, and telephone number. If you are using the Application as a service provider, you must provide us with additional Personal Information as part of the service provider registration process.
When you use the Application, you must provide us with relevant information as we may require for the Application to function, for example:

If you use the Application as a user, you will need to provide us with information regarding the type of service you are seeking, and details regarding booking and/or purchasing ferry tickets.
If you are using the Application as a service provider, in order for the Application to function, you will need to provide us with information about the services you are able to accept at that time, and details about your current services. Once a service order placed by a user is accepted by you as a service provider, you may need to provide us with other data that we require to manage the Application and its ecosystem, and to monitor overall usage of the Application.
If you utilize and/or when payments or transfers are made through the electronic money and/or electronic wallet facilities that we provide, if you are the payer or sender, you will provide us with information relating to such utilization, payment or transfer, including but not limited to the transfer and/or details of the payee, the amount of payment paid, the type of payment card or account used, the name of the issuer of the payment card or account, the name of the holder of the payment card or account, the identification number of the payment card or account, the verification code of the payment card or account and the expiration date of the payment card or account, as applicable.
If you intend to apply as a registered or verified account holder of the electronic money facility we provide, you will provide us with the necessary information including but not limited to your full name, your identity card number, the type of identity card you use for registration, address, gender, place and date of birth, occupation, tax details, citizenship and/or biometric data.
If you intend to add your payment card or account as a source of payment funds in the Application, you will provide us with information regarding the type of payment card or account registered, the issuer of the payment card or account, the name of the payment card or account holder, the payment card or account identification number and the payment card or account verification code and the expiration date of the payment card or account, as applicable.

Information collected whenever you use the Application or visit our website

Whenever you use the Application or visit our website, we may collect certain technical data related to your usage such as, internet protocol (IP) address, information such as the previous or next web pages viewed, duration of each visit/session, internet device identity (ID) or media access control address, mobile advertising ID, and other device information including information regarding the manufacturer, model, and operating system of the device you use to access the Application or our website.
Whenever you use the Application or visit our website, certain information may also be collected automatically using cookies. Cookies are small application files that are stored on your computer or mobile device. We use cookies to track user activity in order to improve the user interface and experience. Most mobile devices and internet browsers support the use of cookies; however, you can adjust the settings on your mobile device or internet browser to decline certain types of cookies or certain cookies. Your mobile device and/or browser will also allow you to delete any cookies that have previously been stored at any time. However, doing so may affect the functionality available on our Application or website.
Whenever you use the Application via a mobile device, we will track and collect your real-time geographic location information. In some cases, you will be asked or required to enable the Global Positioning System (GPS) on your mobile device so that we can provide you with a better experience in using the Application (for example, to provide information about how close a service provider is to you). You can always choose to temporarily disable geographic location tracking information on your mobile device. However, this may affect the functionality available on the Application.
If you utilize and/or when payments or transfers are made through the electronic money and/or electronic wallet facilities that we provide, we may collect certain information related to your source of funds for top-ups (including bank account details), details of the recipient's withdrawal account, transaction history (including recipient details), billing details, invoice details and telephone number details.
If you utilize the virtual account we provide to receive e-money and/or e-wallet payments from payers, whether you are a service provider or a merchant, we may collect certain information related to your usage including but not limited to the services and/or goods transacted, the amount you collect from each transaction, withdrawal or settlement account details, and withdrawal or settlement history.
If you utilize and/or when payments are made through a payment card or account you added in the Application, we may collect certain information related to transaction history (including recipient details), billing details, invoice details and telephone number details.

Information collected from third parties

We may also collect your Personal Information from third parties (including agents, vendors, suppliers, contractors, partners and anyone who provides services to us, who collects your Personal Information and/or performs functions on our behalf, or who collaborates with us). In such cases, we will only collect your Personal Information for or in connection with the purposes of such third party’s engagement or the purposes of our collaboration with such third party (as the case may be). Specifically, when you register for a payment card or account through the Application and/or access, add and/or link a payment card or account to the Application, we may collect certain financial information and your financial history (including but not limited to payment card or account transaction history, payment card or account details and mapping and/or payment card or account status and status) from the issuer of such payment credentials or other third parties.

Information about third parties that you provide to us

You may provide us with Personal Information relating to other third party individuals (including Personal Information relating to your spouse, family members, friends or other individuals). Of course, you will need their consent to do so – see “Acknowledgement and Consent”, below, for more information.
We do not require or endorse, or prohibit, the installation or use of in-vehicle recording devices in any Vehicle. If such devices are installed and used in any Vehicle, we do not collect any Personal Information from any in-vehicle recordings by such devices, and any collection of Personal Information from such in-vehicle recordings is not done on our behalf. The collection of Personal Information from such in-vehicle recordings is at the sole discretion of the service provider. We have no control over the collection of such Personal Information by the service provider and the subsequent use or disclosure by the service provider of such collected Personal Information. If you are a service provider and choose to install and use such in-vehicle recording devices in your Vehicle, it is your sole responsibility to notify users of the same. If you are a user and you have any objection to the use of in-vehicle recording devices in any service provider’s Vehicle, you must notify the service provider directly and it will be your sole responsibility to do so.
When you use the chat feature on our Application, you will provide the phone number of our Application users stored in your mobile phone book so that you can use our chat feature and for other internal purposes.

2. USE OF PERSONAL INFORMATION WE COLLECT

We may use the Personal Information collected for the following purposes as well as for other purposes permitted by applicable law (“Purposes”):

If you are a user, we may use your Personal Information:

To identify you and register you as a user and to manage, verify, deactivate or administer your account;
To facilitate or enable any verification as we in our sole discretion deem necessary before the service provider provides you with services or before we register you as a user, including conducting Know Your Customer (KYC) and credit assessments;
To enable service providers to provide you with services as you request;
To process and facilitate orders and payment transactions you make, including where applicable, transactions made through any payment card or account available through the Application;
To notify you about any transactions or activities that occur within the Application or other systems connected to our Application;
To communicate with you and send you information in connection with your use of the Application;
To notify you about any updates to the Application or changes to the services available;
To process and respond to inquiries and feedback received from you;
To maintain, develop, test, improve and personalize the Application to meet your needs and preferences as a user;
To monitor and analyze user activity, behavior, and demographic data including trends and usage of various services available on the Application;
To process and manage your reward points;
To offer or provide services from our affiliates or partners; and
To send you direct or targeted marketing communications, advertisements, vouchers, surveys and information about special offers or promotions.

If you are a service provider, we may use your Personal Information:

To identify and register you as a service provider and to manage, administer or verify your Account;
To facilitate or enable any verifications we deem necessary in our sole discretion before we register you as a service provider, including for KYC and credit assessment;
To enable you to provide services to users;
To process, facilitate and settle payments due to you in connection with any services you have provided;
To communicate with you and send you information in connection with the provision of your services, including conveying user orders to you and facilitating your acceptance of those orders;
To provide you with notices and updates regarding the Application or changes to the way the service is provided;
To provide you with reports regarding the Services you have provided;
To process and respond to feedback from users regarding the services you provide;
To maintain, develop, test, improve and personalize the Application to meet your needs and preferences as a service provider;
To monitor and analyze user activity, behavior, and demographic data including trends and service provider responses for various services available on the Application;
To process and manage your reward points;
To offer or provide services from our affiliates or partners;
To send you marketing communications, advertisements, promotions, surveys, and direct or targeted information about special offers or promotions.

Whether you are a user or service provider or provide Personal Information to us, we may also use your Personal Information more generally for the following purposes (although in each such case we will always act reasonably and not use more Personal Information than is necessary for the particular purpose):

To perform related business processes and functions;
To monitor usage of the Application and manage, support and improve the performance efficiency, growth, user experience and functionality of the Application;
To provide assistance in connection with and resolve any technical difficulties or operational problems with the Application or services;
To generate statistical information and analytical data for the purposes of testing, research, analysis, product development, commercial partnerships and collaboration;
To prevent, detect and investigate any prohibited, illegal, unauthorized or fraudulent activities;
To facilitate business asset transactions (which may include mergers, acquisitions, or asset sales) involving us and/or our affiliates; and
To enable us to comply with our obligations under applicable law, including but not limited to responding to regulatory inquiries, investigations or directives, complying with regulatory filing, reporting and licensing requirements, and conducting audits, due diligence and investigations.

3. SHARING OF PERSONAL INFORMATION WE COLLECT

We may disclose, allow access to, or share with affiliates and other parties your Personal Information for any of the following purposes as well as for other purposes permitted by applicable law:

If you are a user, for the purposes of enabling the service provider, to perform or provide services;
If you are a service provider, for the purposes of enabling users to request or receive services from you;
Where required or permitted by applicable law (including but not limited to responding to regulatory inquiries, investigations or directives, or complying with statutory or regulatory reporting and reporting requirements, and licensing requirements), for the purposes specified in such applicable law;
If instructed, requested, required or authorized by a government authority, for purposes as set out in applicable government policies, regulations or laws;
If there is any form of legal process between you and us, or between you and any other party, in connection with, or related to the services, for the purposes of that legal process;
In connection with any verification that we or other third parties deem necessary before the service provider provides you with services or we register you as a user, including for KYC and credit assessment;
If we enable our services on third party platforms, (i) to help us obtain your Personal Information and/or (ii) to register you or allow you to use our services from such platforms.
In the event of an emergency involving your safety (whether you are a user or a service provider) for the purposes of dealing with that emergency;
In situations concerning your health or public interest (whether you are a user or a service provider), we may share your Personal Information with government authorities and/or other agencies that may be appointed by government authorities or have partnerships with us, for the purposes of contact tracing, supporting government initiatives, policies or programs, public safety and other purposes that are reasonably necessary;
In connection with, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into another company, for the purposes of such transaction (even if such transaction is not ultimately consummated);
In connection with insurance claims, we will share your Personal Information for the purpose of processing insurance claims to insurance companies that work with us;
To third parties (including our agents, vendors, suppliers, contractors, partners and anyone who provides services to us or you, performs functions on our behalf, or has a commercial relationship with us) for or in connection with the purposes of such third party engagement, to make certain disclosures to the relevant third party that are technically necessary to process your transactions or for the purposes of our collaboration with such third party (as the case may be), which may include allowing such third party to introduce or offer products or services to you, authenticate you or connect with your Account, or perform other activities including marketing, research, analysis and product development; and
If we share Personal Information with affiliates, we will do so for the purposes of them helping us provide the Application, operating our business (including, if you have subscribed to our mailing list, for direct marketing purposes), or for the purposes of them performing data processing on our behalf. All of our affiliates are committed to processing the Personal Information they receive from us in accordance with this Privacy Policy and applicable law.

If it is not necessary for Personal Information to be associated with you, we will use reasonable efforts to eliminate the means by which Personal Information can be associated with you as an individual before disclosing or sharing that information.
We will not sell or rent your Personal Information.
Other than as set out in this Privacy Policy, we may disclose or share your Personal Information if we notify you and we have obtained your consent for such disclosure or sharing.

4. STORAGE OF PERSONAL INFORMATION

Your Personal Information will only be retained for as long as it is necessary to fulfill the purposes for which it was collected, or for as long as such retention is required or permitted by Applicable Law. We will cease retaining Personal Information, or remove the means by which Personal Information can be associated with you as an individual, as soon as it is reasonable to assume that the purposes for which the Personal Information was collected are no longer being served by retention of the Personal Information and retention is no longer necessary for legal or business purposes.
Please note that it is still possible that some of your Personal Information may be retained by other parties, including by government agencies in certain ways. If we share your Personal Information with authorized government agencies and/or other agencies that may be appointed by government authorities or have cooperation with us, you agree and acknowledge that the retention of your Personal Information by the relevant agencies will follow their respective data retention policies. Information submitted through communications between users, service providers conducted other than through the use of the Application (such as through telephone calls, SMS, mobile messages or other communication methods and the collection of your Personal Information by our agents) may also be retained in some ways. We do not encourage the retention of Personal Information in such manner and we are not responsible to you for the same. We shall not be liable for such retention of your Personal Information. You agree to indemnify, defend and hold us, our officers, directors, employees, agents, partners, suppliers, contractors and Affiliates harmless from and against all claims, losses, liabilities, expenses, damages and costs (including but not limited to legal fees and expenses on a full indemnity basis) arising directly or indirectly from the unauthorized retention of your Personal Information.

5. ACCESS AND CORRECTION OF PERSONAL INFORMATION

Subject to applicable law, you may request us to access and/or correct your Personal Information in our possession and control, by contacting us at the details provided below.
We reserve the right to refuse your request to access or correct some or all of your Personal Information in our possession or control if permitted or required by applicable law. This may include circumstances where the Personal Information may contain references to other individuals or where the request for access or request for correction is for reasons that we consider frivolous, unimportant or vexatious.

6. CROSS-BORDER DATA TRANSFER

When you use our Application and services in other countries where our Application is also accessible (“Designated Country”), we may transfer your Personal Information from your country of origin (“Origin Country”) to the Designated Country to enable and ensure a seamless customer experience when you use our Application abroad. In such cases, we will seek your consent to transfer your Personal Data from the Origin Country to the Designated Country to ensure compliance with applicable laws and regulations.
Your Personal Information may also be stored or processed outside your country by our personnel working for us in other countries, or by our third party service providers, vendors, suppliers, partners, contractors or Affiliates.
We will comply with applicable laws and regulations and use all reasonable efforts to ensure that our overseas Affiliates and all such third party service providers provide a level of protection comparable to our commitments under this Privacy Policy.

7. SECURITY OF YOUR PERSONAL INFORMATION

The confidentiality of your Personal Information is of utmost importance to us. We will use all reasonable efforts to protect and secure your Personal Information against unauthorized access, collection, use or disclosure and against unlawful processing, accidental loss, destruction and damage or similar risks. Unfortunately, the transmission of information over the Internet is not completely secure. Although we will do our best to protect your Personal Information, you acknowledge that we cannot guarantee the integrity and accuracy of any Personal Information you transmit over the Internet, or guarantee that such Personal Information will not be intercepted, accessed, disclosed, altered or destroyed by unauthorized third parties, due to factors beyond our control. You are responsible for maintaining the confidentiality of your account details and you should not share your account details, including your password and One Time Password (OTP), with anyone and you must always maintain and take full responsibility for the security of the devices you use.

8. CHANGES TO THIS PRIVACY POLICY

We may review and change this Privacy Policy in our sole discretion from time to time, to ensure that it is consistent with our future developments, and/or changes in legal or regulatory requirements. If we decide to change this Privacy Policy, we will notify you of such changes by means of a general notice posted on the Application and/or website, or to the email address specified in your account. You agree that it is your responsibility to review this Privacy Policy periodically to obtain the latest information on our data processing and data protection practices, and that your continued use of the Application or website, communications with us, or access to and use of the services following any changes to this Privacy Policy will constitute your acceptance of this Privacy Policy and all changes.

9. ACKNOWLEDGEMENT AND CONSENT

By agreeing to the Privacy Policy, you acknowledge that you have read and understood this Privacy Policy and that you agree to all of its terms. In particular, you agree and consent to us collecting, using, sharing, disclosing, storing, transferring, or otherwise processing your Personal Information in accordance with this Privacy Policy.
In circumstances where you provide us with Personal Information relating to another individual (such as Personal Information relating to a spouse, family member, friend or other party), you represent and warrant that you have obtained the consent of that individual to, and hereby consent on behalf of that individual to, our collection, use, disclosure and processing of their Personal Information.
You may withdraw your consent for any or all collection, use or disclosure of your Personal Information at any time by giving us reasonable notice in writing using the contact details set out below. You may also withdraw your consent for us to send you certain communications and information through the “opt-out” or “unsubscribe” facilities contained in our messages to you. Depending on the circumstances and nature of the consent you withdraw, you must understand and acknowledge that upon withdrawal of such consent, you may no longer be able to use the Application or services. Your withdrawal of consent may result in the termination of your account or your contractual relationship with us, with all rights and obligations arising therefrom remaining fully reserved. Upon receipt of your notice to withdraw consent for any collection, use or disclosure of your Personal Information, we will inform you of the potential consequences of such withdrawal so that you can decide whether you wish to withdraw your consent.

10. MARKETING AND PROMOTION MATERIALS

We and our partners may send you direct marketing, advertising and promotional communications via push notification applications, in-App messages, post, telephone calls, short message service (SMS), chat platforms, social media, Chat Platforms and Social Media, and email (“Marketing Materials”) if you have agreed to subscribe to our mailing list, and/or consented to receive marketing and promotional materials from us. You may opt out of receiving such marketing communications at any time by clicking on the “unsubscribe” facility embedded in the relevant message, or contacting us using the contact details set out below. Please note that if you opt out, we may still send you non-promotional messages, such as travel receipts or information about your account.

11. ANONYMOUS DATA

We may create, use, license, or disclose Personal Information, provided, however, that (i) all identifiers have been removed so that the data, alone or in combination with other available data, cannot be associated with or linked to or cannot identify any person, and (ii) it has been combined with similar data so that the original data is part of a larger data set.

12. THIRD PARTY PLATFORMS

The Application, website and Marketing Materials may contain links to websites operated by third parties. We do not control or accept responsibility for these websites and for the collection, use, maintenance, sharing or disclosure of data and information by such third parties. Please read the terms and conditions and privacy policies of such third party websites to learn how they collect and use your Personal Information.
If you use our App and enable fingerprint and/or facial recognition features on your mobile device for authentication purposes, please note that we do not store such biometric data. Unless otherwise notified to you, such data is stored on your mobile device and may also be stored by third parties, such as your device manufacturer. You agree and acknowledge that we are not responsible for any unauthorized access to or loss of biometric data stored on your mobile device.
Advertisements contained on our Application, website or Marketing Materials operate as links to the advertiser's website and as such any information they collect based on your clicking on such links will be collected and used by the relevant advertiser in accordance with that advertiser's privacy policy.

13. HOW TO CONTACT US

If you have any questions regarding this Privacy Policy or you would like to gain access to your Personal Information, please contact cs.roro@prahu-hub.com

For other questions or complaints, you can contact us via email or telephone at the following contacts:

E-mail

For Customer and Partner Support: cs.roro@prahu-hub.com

Call Center

For Customer and Partner Support: +62 811-3229-1988

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