1. Types of Personal Data Collected

Personal Data refers to any information that can be used to identify an individual directly or indirectly. This definition includes Personal Data collected offline, through direct marketing campaigns, sweepstakes, competitions, and online through our website, applications, and branded pages on third-party platforms, as well as applications accessed or used via third-party platforms.

You are not required to provide the Personal Data requested by Samora Group. However, if you choose not to do so, the Company may not be able to provide you with high-quality products or services.

In general, Samora Group may collect the following types of Personal Data:

a) Personal contact information, such as name, email address, physical address, date of birth, and phone number;

b) Account login details, such as User ID, email address, and password;

c) Demographic information, such as age, gender, and lifestyle preferences. Lifestyle preferences may include your preferences for certain products we offer and your interests related to those products;

d) Browser history, such as accessed pages, access dates, location at the time of access, and IP address;

e) Payment information for purchases made on any Samora Group website. Payment information typically includes the user's billing name, billing address, and payment details such as credit card details or bank account number;

f) If you have applied for a job with Samora Group, the Company may collect additional Personal Data such as employment history, educational background, and job references.

2. Methods of Personal Data Collected

We may collect personal information from you through various means, including but not limited to:

a) Information you provide directly, such as when you fill out a form, apply for a job, or contact us;

b) Automatically collected information when you visit the Samora Group website, through the use of cookies and other tracking technologies

Samora Group collects information from various sources in accordance with applicable regulations, including Personal Data and/or Transaction Data obtained by Samora Group, whether new or historical data, to ensure that the Company continues to provide the best service to Site Users. By doing so, you agree and authorize:

I. Group to use the Personal Data and/or Transaction Data you provide to Samora

II. Samora Group to disclose, provide, transmit, and share Users' Personal Data and/or Transaction Data with companies under Samora Group and its affiliates. Providing Personal Data is voluntary; however, if you do not provide accurate Personal Data, the Company may not be able to provide services effectively

3. Use of Personal Data and/or Transaction Data

By accessing the Site, you explicitly consent to Samora Group's use of your Personal Data and/or Transaction Data for website usage, business operations, and other purposes, including but not limited to:

a) Responding to inquiries, comments, or complaints;

b) Communicating with Users through various media, such as on-site notifications, email, phone, SMS, chat services, in-app messaging/push notifications, and social media;

c) Marketing and promoting our products/services and/or Samora Group companies, including announcements, promotional materials, greetings, invitations to participate, and privileges from Samora Group companies, partners, sponsors, or advertisers;

d) Processing Users’ participation in contests, games, promotions, polls, or surveys;

e) Understanding and analyzing usage patterns and product/service sales according to User needs and preferences;

f) Developing, improving, and providing products and services tailored to User needs;

g) Internal administrative processes such as audits and taxation

Samora Group will make reasonable efforts to protect Users' Personal Data and/or Transaction Data. Samora Group remains committed to enhancing site security standards. However, Samora Group is not responsible for losses caused by damage or loss of Personal Data and/or Transaction Data that occurs beyond our control. Therefore, Samora Group strongly recommends that you regularly update your account and software and maintain the confidentiality of your account password.

4. Disclosure of Personal Data and/or Transaction Data

By accessing the Samora Group site, you have directly consented to the Company’s use of your Personal Data and/or Transaction Data for business, operational, or other purposes with Third Parties, including but not limited to:

a) Research and marketing companies related to the promotion of our products/services;

b) Information technology service providers (including infrastructure services, cloud computing, software, big data analytics, machine learning, and services such as data cleansing, data insight, and credit scoring);

c) Payment transaction processing service providers, including payment gateway operators, fund transfer providers, e-wallets, e-money providers, and other payment system providers related to transactions conducted on the Site;

d) Service providers or Samora Group partners related to products and services offered on the Site;

e) Professional advisors and external auditors, including legal advisors, financial advisors, and other consultants

f) Government authorities, both within and outside the jurisdiction of the Republic of Indonesia, in accordance with applicable laws and regulations;

g) Other parties as required by applicable laws and regulations.

5. Use of Cookies

Cookies are small files automatically placed on a User’s device when accessing the Site. Cookies help the Company understand which parts of the Site are most frequently visited and Users’ preferences. Cookies enable the Company to tailor Site content to be more relevant to User needs

Samora Group uses Cookies for Site security and to facilitate re-registration for Users. Users have full rights to change Cookie usage settings in their browser. However, please note that disabling Cookies may affect the functionality of some Site features.

6. Management and Security of Personal Data

Samora Group highly values Users’ Personal Data and/or Transaction Data and is committed to making reasonable efforts to protect all Personal Data and/or Transaction Data. The Company continues to improve Site security standards. However, Samora Group is not responsible for damages resulting from unauthorized disclosure or misuse of your Personal Data and/or Transaction Data that occurs beyond the Company’s control. Therefore, Samora Group recommends that you regularly update your Site account and software and never disclose your Site account password to others.

By using the Site, you expressly agree that Samora Group may send, store, use, and process your Personal Data and/or Transaction Data on servers located in data centers designated by the Company. These data centers may be managed by third parties and/or located outside the Republic of Indonesia. Nevertheless, the use of your Personal Data and/or Transaction Data in connection with the Site will still be governed by this Privacy Policy in accordance with applicable Indonesian regulations. Samora Group will retain your Personal Data and/or Transaction Data until a specific request for account deletion is made.

7. Policy Changes

By registering, accessing, and/or using the Site, you are deemed to have read, understood, and explicitly agreed to the Samora Group Privacy Policy. You also declare and guarantee that the Personal Data provided to the Company is accurate, complete, lawfully obtained, and that you have full rights to provide it to Samora Group

Samora Group reserves the right to amend this Privacy Policy at any time by displaying a notification on the Site. Users are deemed to accept and agree to the changes upon accessing and using the Site. Therefore, the Company encourages Users to periodically review the Site for the latest information on the application of this Privacy Policy. Users are responsible for staying informed of any changes made by Samora Group from time to time.

For more information regarding Site usage, submitting complaints, or requesting corrections and deletions of Personal Data, you can contact Samora Group via email at corpcomm@samoragroup.co.id or call +62 21 3983 0018.

1. User Terms

a) All copyrights and intellectual property rights including, but not limited to, Trademarks, text, images, sounds, videos, software, and other materials contained on the Site and its display pages, as well as the information and materials therein, are owned by Samora Group and protected by copyright laws, treaties, and regulations in the Republic of Indonesia. Users are prohibited from using materials contained on the Site outside of what is permitted in these Terms and expressly by laws and regulations, including but not limited to duplication, distribution, modification, public broadcasting, reuse and/or transfer.

b) Samora Group is not responsible and is released from any claims, consequences, demands for compensation, or other consequences that arise regarding the operational reliability, functionality, content, or fulfillment of user needs for the use of electronic systems downloaded from the Site;

c) Samora Group is not responsible for problems caused by incorrect configurations, electronic systems, or interfaces or functions not developed by Samora Group;

d) You are prohibited from using services in electronic systems for matters prohibited by applicable laws and regulations;

e) You are not allowed to harm or misuse the Site in any way. You are not allowed to alter or modify the Site without written permission from Samora Group. Samora Group reserves the right to terminate your Site account usage if you use the Site without complying with the Terms and Conditions of Use;

2. Ownership Terms

a) You cannot modify or copy materials, use materials for commercial purposes, or for public display (commercial or non-commercial), attempt to decompile or reverse engineer software on the Site, remove any copyright or other proprietary notices from materials, or transfer materials to others on other servers. Any permission to download electronic systems contained within the Site will refer to the terms of use and privacy policy of each electronic system.

b) You are only allowed to use the Site and all its features solely for your company's internal needs and non-commercial purposes

c) Samora Group strives to maintain the security and reliability of the Site from time to time, but Samora Group is not responsible for any damage, loss, or other harm caused by User access or use of the Site or any downloads of any materials, data, text, images, video, or audio from the Site.

3. Received Information

a) In accordance with Samora Group's Privacy Policy, any materials, data, questions, comments, suggestions, or similar items that you submit to the Site via electronic mail or other media will be treated as non-confidential and non-proprietary and may be used by Samora Group for any purpose, including but not limited to reproduction, disclosure, transmission, publication, broadcasting, and posting. Additionally, Samora Group has the right to use, without compensation and any liability to you, any ideas, concepts, knowledge, or techniques contained in any information you submit to the Site for any purpose.

b) You are prohibited from sending materials that are illegal, threatening, defamatory, contain pornographic elements, or any material that constitutes or encourages actions that would be considered a criminal offense or give rise to civil liability.

c) Samora Group will cooperate with any law enforcement officials or comply with court orders or other authorized agencies requesting or directing Samora Group to disclose the identity of anyone submitting such materials.

4. Limitation of Liability

Samora Group is not responsible for any damages, including direct, indirect, special, or occasional, as well as costs incurred related to the use or inability to use the Site, or due to failure, error, interruption, virus, or connection/system issues.

5. Personal Data Protection

To protect privacy rights in accordance with applicable regulations and improve service quality, you, as the owner of Personal Data, give consent to Samora Group to:

a) Protect Personal Data

Implement systems, procedures, technical devices, and other measures deemed necessary in accordance with legal provisions to maintain the security of your Personal Data

b) Personal Data Management

Obtain, manage, store, and destroy your Personal Data, including cooperation with information technology service providers or other third parties.

c) Providing Access to Related Parties

I. Provide access to Samora Group subsidiaries, affiliates, Company partners, professional advisors, external auditors, and legal and financial consultants to use User Personal Data, such as for data analysis, website hosting, and communication with Users through various communication channels.

II. You hereby agree that Samora Group may send, store, and process your Personal Data on servers located in data centers designated by Samora Group, which may be managed by third parties and/or located outside the territory of the Republic of Indonesia.

d) Data Disclosure in Special Situations

Samora Group may disclose or use your information in the following conditions:

I. To support the defense process against legal claims or demands

II. To comply with court orders or legal processes.

III. For investigation of fraud cases or other legal violations

IV. To ensure compliance with applicable provisions on Samora Group products and services.

V. To protect the rights, property, or security of Samora Group, service users, or other parties related to Samora Group policies

VI. In other situations permitted by Indonesian laws and regulations