Last update: 30 April 2021
Achiko AG, a company incorporated with limited liability in Switzerland with business identification number (UID) CHE299698976, having its registered office at Tessinerplatz 7, 8002 Zurich, Switzerland (“the Company” or “We”).
We recognise the importance of Your privacy, and that You have a right to control how Your personal information and sensitive information (“Your Data”) are collected and used.
COLLECTION OF YOUR DATAWhat Do We Collect ?
Your Data from users of Person App/Health Partner App/Business Partner App of Achiko’s “Teman Sehat” platform Apps, including but not limited to:
- Contact details which may include Your name, address, email and telephone details;
- Age or date of birth information;
- Your Data that You include in any content that You enter or upload onto the Apps such as Your name, Identity Number (NIK) as printed on the identity card number (or commonly known as ‘KTP’), company name and location/Your or Your representative’s business, location data, photographs or other information about You;
- Sensitive information or special categories of personal data (as defined in the relevant Privacy Regulations), which in this case is health data, namely the Health Testing result that You choose to provide to Us, however only if you voluntarily choose to disclose them to Us through Achiko website and Application.
- Information regarding Your use of the Achiko website and the Apps, including IP address, standard web log information including online usage, and other information or online analytics regarding the use of the Achiko website and the Apps, unless You object to the processing in accordance with the rights is in the Privacy Laws;
- Information about Your transactions/dealings with Achiko, including details of the services that we have provided to You or that You have asked about, including additional information required to deliver such services and respond to Your inquiries; and
- Any additional information relating to You that You provide to Us when You contact Us in connection with
Your use of the Achiko website and the Apps including inter alia:
- GPS Location
- Read and write internal/external storage of Your cellular,
- In the case of a Person App user, this may also include:
- information on Your geographic location when You use the check-in function to check-in at places owned by/organaized/under responsibilty of Business Partner, and/or venues (“Places and/or venues”) and details of the date and time of Your visit (“Check-in”); and
- information about Your health, including Health Testing result, that appears on medical documentation that You provide to Us or that You agree for Us to obtain (including directly from Your Health Partner provider), or where permitted by law; and
- In the case of doctors, nurses and other medical professionals who perform Health Testing on a Person App user, their name and the fact that they have performed Health Testing; and
- In the case of staff Checking-in for a Person App user, their name and the fact that they have performed that Check-in.
HOW DO WE COLLECT YOUR DATA ?
Directly from You, someone acting on Your behalf, or from third parties (which have obtained Your consent to disclose
Your Data), through:
Your use of Achiko websites and the Apps, including:
when You register for an account or create a profile as:
- Person App user;
- hospital/clinic/laboratory representatives on the Health Partner App;
- representatives of companies/Places or venues for worshipping/public facilities on the Business Partner App;
- a staff member or personnel from venues of the Business Partner App user;
- hospitals or other medical professional of the Health Partner App user;
- when You register for an account or create a profile as:
use of the “Teman Sehat” platform by other users, including:
- a staff member at a hospital, medical professional or other testing facility where a Person App user is
tested for COVID-19 (Health Testing provider) may submit:
- 01 Health Testing Result and other health information about Person App users; and
- 02 information about the medical professional who conducted the testing, via the Health Partner App; and / or
- staff at Places and/or venues visited by the Person App user can submit:
- information about their visits to Places and/or venues via the Business Partner App when the Person App user scans the QR code on their Person App when they enter the Places and/or venues; and
- information about the staff member checking in the QR code, on the Business Partner App;
- information that You communicate to Us including through correspondence, chat, services or websites, e- mail, telephone, third party applications and all other forms of communication sent or given to us electronically or in printed form;
- interactions with Our services, content and advertisements;
- orders for products or services;
- third party service providers;
- providing service and support to customer (including Customer Service); and
- participate in trade promotions through the Person App and Business Partner App conducted by Us, on Our behalf or through other users on the “Teman Sehat” platform.
- a staff member at a hospital, medical professional or other testing facility where a Person App user is tested for COVID-19 (Health Testing provider) may submit:
- Your use of Achiko websites and the Apps, including:
- If from other people (for example from someone who supplies services to Us), We will ensure You know that We have collected Your Data and the conditions surrounding the collection and provide additional disclosures required under the applicable Privacy Laws.
PURPOSE OF USE OF YOUR DATA
- To supply services to end user of Our websites and App;
- To assist Indonesian government authorities with COVID-19 contact tracing efforts (if there is a case of exposure );
- To manage Your account with Us , including to help Person App users (i) to book for Health Partner Testing; (ii) obtaining notification of Health Testing result from Health Partner; (iii) Checking-in at Places and/or venues; (iv) may oftenly having health checking in a more focused way in this case by having Health Testing, to the benefit of themselves, their families, surroundings and wider communities;
- to manage and ensure interconnectivity within the “Teman Sehat” platform, including the ability for:
- Health Partners, by using the Health Partner App, (i) obtaining Your Data from Health Testing; (ii) record the result of Health Testing and testing for other types of infection (to the extent possible) in a format determined by Achiko; (iii) may convey the information as set out in item (ii) to the Person App user; and/or
- Places and/or venues, by using Business Partner App (i) acccess information regarding Person App user; and (ii) to confirm the identity and validate status of their Health Testing result when checking-in, to filter Person App users who may Check-in so that Places and/or venues may maintain its safe and comfortable business environment; and/or
- representatives of the Indonesian government to assess status of Health Testing Result of Person App users, and their trail between different Places and/or venues;
- to provide You with services You have requested;
- to respond to enquiries from You;
- to assess and process warranty claims;
- to enforce the agreement between You and Achiko;
- to undertake research and analyze statistical information generated using Your Data (including health data) to measure and improve the performance of the “Teman Sehat” platform;
- to communicate updates or orders with You;
If You do not provide Us with the information We ask for, We may not be able to fulfill the applicable data collection purposes, such as to supply services to You. This may include (but is not limited to) restricted access to certain Places and/or venues on Business Partner App; and inability to access some of the benefits available (e.g. in Health Testing booking service) on the Person App.
EXCLUSION OF USE OF YOUR DATA
We will only use or disclose Your Data for purposes other than those for which it was collected or related purposes if You have consented to such different use or to disclosure to the extent that such use or disclosure is permitted by applicable law.
In conducting Our business, it may be necessary to share Your Data with and between Our affiliates (including subsidiaries and controlled entities) and related corporate bodies and also between organizations that provide services to Us (for example, Our alliance partners). We will not disclose Your Data to organizations other than those set out in this Policy, unless:
- required or permitted by law;
- we believe it is necessary to provide service You have requested;
- it is necessary to protect the rights, property or personal safety of each of Our customers, community, or Our interests;
- Our assets and business operations are transferred to another party as a business continuity; or
- You have given Your consent.
HOW DO WE USE AND DISCLOSE YOUR DATA?Compliance with the Applicable Law:
- We will only use and disclose Your Data in accordance with the Privacy Laws and in accordance with this Policy.
- In some cases, We are required to collect Your Data in order to comply with the prevailing laws and regulations.
- We may disclose Your Data outside the jurisdiction from which it was collected. In conducting Our business, we transfer to, hold or access Your Data from various countries including Indonesia. The privacy laws of these countries may not provide the same level of protection as the privacy laws of the countries where Your Data is collected. However, this does not change Our commitment to safeguard Your privacy and we will comply with all applicable laws relating to cross-border data disclosure.
Who Can We Share Your Data With?
Your Data shall be used in several application under “Teman Mitra Kesehatan” platfrom Achiko:
- the Person App – used by Person App Person App user to book Health Testing; receive and manage Health Testing result and Check-in by sharing their Health Testing result status set-out in the specified format. Person App user can indeed choose not to save Your Data with Us, however, please be aware that should You choose not to save it, when You will book a Health Testing the user must refill and re-submit the required data, including name, NIK, address and place, date of birth;
- the Business Partner App – used by and at Places and/or venues with the main function as Digital Guest Book and validate the Health Testing Result on the Person App when Check-in and determine whether the person acceptable at the Places and/or venues. Check-in data according to its function and utilization, will only be stored for fourteen (14) days and will be deleted afterwards, when no exposure case is found;
- the Health Partner App – used by Health Partner (that function as hospitals, clinics and/or medical professionals) to upload Health Testing result and relevant medical treatment information (to the extent permitted by applicable law) concerning Person App users having a form of digital health passport namely My Health Passport also known as My Health Pass, wherein installed several supporting functions (i) QR code; (ii) Badges marked with color are embedded digitally, each of which has a validity period which will continue to conform to the provisions and policies of the Government. Green (tested, negative results and validity period), Yellow (not tested or the validity period of the Health Testing result has ended or possibly been exposed) and Red (tested, Positive results exposed) accompanied by notes to carry out regular procedures (SOP) by the Government;
- Service Providers
Like most major organizations, we use a variety of service providers to help us maximize the quality and efficiency of Our services and business operations. This means that individuals and organizations outside of Achiko, such as cloud and web hosting service providers, software as a service provider, IT support service providers, analysis and marketing support service providers, and online payment system providers, will sometimes have access to or being discloses Your Data that we hold and can only use it on Our behalf to facilitate Our services, provide services on Our behalf, perform service-related services or assist us in analyzing how Our services are used. We ask Our service providers to adhere to strict privacy guidelines which require service providers not to retain this information, or use it or disclose it for unauthorized purposes.
- Direct Marketing
We do not send email marketing materials to current or prospective customers for the purpose of the Apps. However, We may send promotional materials about places or other business partners that may be of interest to You through the Person App itself.
Our Website and Term of Use Policy
- Links to Other Websites and Other Third Party Collections.
Our website and Apps may contain links to third party websites or references to third party applications. These linked sites and applications are not under Our control and we are not responsible for the content of these sites and these sites or applications are not subject to Our Policy. Before disclosing Your Data on other websites or applications, we recommend that You check the terms and conditions and the relevant site’s Policy. Achiko is not responsible for any practices on third party websites or applications that may violate Your privacy.
HOW DO YOU ACKNOWLEDGE AND AGREE THE USE OF YOUR DATA
AND APPLICATION WHICH CONTAINS OF YOUR DATA ?
Person App User:
- by clicking ‘agree’ to this Policy and using the Person App to Check-in at the Place or venues, You consent to the status of Your Health Testing Result being disclosed to the Places and/or venues and the details of Your visit being collected, used and disclosed by Achiko in a manner set forth in this Policy (including without limitation disclosure to the Government of Indonesia and the appointed Government representatives, if there is a case of exposure).
Health Partner App User:
- by clicking ‘agree’ to this Policy and using the Health Partner App to record Health Testing Result and other types of infection from the Person App user, You consent to these results and the related health information collected including Your staff/medical personnel information, to be used and/or disclosed by Achiko in specified procedure as set out in this Policy (including without limitation disclosure to Business Partner App user visited by Person App User when checking-ins; and disclosures to the Government of Indonesia and the appointed Government representatives, if there is a case of exposure); and
- must not submit information to the Health Partner App and/or My Health Pass of any Person App Person App user, unless they have first provided a copy of this Policy to the individual concerned.
Business Partner App User:
- by clicking ‘agree’ to this Policy and using the Business Partner App to access information about Person App users and validating their Health Testing Result based on their Digital Health Passports, You consent for information on business venues/place including Your staff/legally representatives collected, used and disclosed by Achiko in the manner specified in this Policy; and disclosure to the Person App User a party who Checking-in; and disclosures to the Government of Indonesia and approved Government representatives, if there is a case of exposure); and
- must not submit information to the Business Partner App about any Person App Person App user who carried out a Check-in unless they have first provided a copy of this Policy to the individual concerned.
- For the using and/or benefiting of Direct Marketing, Access to the Website and Enforcement of Policies and Links to Other Websites and Other Third Party Collections, each and every users by clicking ‘agree’ to this Policy therefore express that You consent to the use of Your Data.
WHAT ARE YOUR RIGHTS IN THE PROCESSING OF YOUR DATA?
Accessing and Correcting Your Data:
- Access. You can have the right to request a copy of Your Data that we process, which we will give back to You in electronic form. For Your own privacy and security, in Our discretion, we may ask You to prove Your identity before providing the requested information. If You require multiple copies of Your Data, We may charge a reasonable administration fee.
- Correction. You can have the right to have incomplete or inaccurate Your Data that we process to be corrected.
- Deletions. You can have the right to request that we delete Your Data that we process, unless we are not obliged to do so if we need to retain that information to fulfill a legal obligation or to build, carry out or defend a legal claim. If You wish to delete Your Data, please contact us at Our email address below and we will take all reasonable steps to delete it unless we need to keep it for legal reasons. You should note that You can update the content and specific account details directly on the Achiko website and the App.
- Confidential. You can determine whether Your Data should be treated as confidential.
Rejecting a Process:
- In the event of Direct Marketing:
If you receive information from Us and do not wish to receive this information any longer, You may reject it.
In the event of receving cookies:
- You can prevent the use of Google Analytics cookies by adjusting the settings on Your browser software. This shall mean You may not be able to fully use all functions of the Website and/or Application.
- In the event of Direct Marketing:
- Send your inquiry to Us at email@example.com
- JIf You wish to prevent the collection of Google data generated by Your use of the Websites (including Your IP address), please download and install the Browser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=enAlternatively, You can find out how Google Analytics uses Your Data when You use Our Website, at https://policies.google.com/technologies.
RETENTION AND SECURITY OF YOUR DATARetention
- We will retain and process Your Data only as long as it is necessary for the purposes for which it was collected.
- We will retain and use Your Data to the extent necessary to comply with Our legal obligations and exercise Our legal rights (for example, if we are required to retain Your Data to comply with applicable laws), resolve disputes and enforce agreements and legal policies.
- When we no longer need to use Your Data or retain it in accordance with legal obligations in order to exercise Our legal rights, we will delete it from Our systems and records or take steps to anonymize it so that You can no longer be identified from it in accordance with relevant Privacy Laws.
- We will endeavor to implement appropriate technical and organizational measures to maintain the security of any information we have about You, and to keep this information accurate, current and complete, and to ensure a level of security appropriate to any possible risks. related to the processing activities described in this Policy.
- Your information is retained on secure servers that are protected in controlled facilities. These are third-party data retention services, including cloud service providers.
- Where it is required by law or relevant government agencies, We will only store Your Data in controlled facilities within Your jurisdiction.
- We take all reasonable physical, administrative and technological precautions to retain and transmit data securely,
for example, personal data is encrypted and retained with a reputable data retention provider. Other steps include:
- computer firewall protection; and
- computer maintenance to prevent unauthorized access.
- Apart from technological measures, Achiko also places access control on employees and other partners. Our employees are subject to contractual confidentiality obligations that are consistent with this Policy. Notwithstanding these steps, Achiko cannot guarantee that the information described in this Policy will be completely secure.
If You have a problem or complaint about how we handle Your Data, or if You have any questions about this Policy, please contact Us at firstname.lastname@example.org or at the address below:
Tower A, Floor 1
Jl. Let. Jend. S. Parman Kav. 62-63, Jakarta Pusat 11410, Indonesia
Attn.: Customer Service
In most cases, We will ask You to submit a request in writing to Us. We will investigate Your complaint and will use reasonable endeavors to respond to You in writing within 30 days of receiving the written complaint. If We fail to respond to Your complaint or if You are not satisfied with the response You receive from Us, You must understand that You may also have the right to lodge a complaint with the applicable privacy authority.
We operate in a dynamic business environment. Over time, aspects of Our business may change as we respond to changing market conditions. This may require that Our policies be reviewed and revised.
We reserve the right to change this Policy at any time and notify You by posting the latest version of the policy on the Achiko website and App for Your consent. If at any time we decide to use Your Data in a way that is different from what was stated when it was collected, We will notify the user via email or through an important notification on Our website for Your consent.
This Policy is prepared in English and Indonesian. Both texts are equally original. In the event of an inconsistency or difference in interpretation between the English text and the Indonesian text, the relevant Indonesian text will be deemed to be automatically amended to conform with and to make it consistent with the relevant English text.
By click ‘agree’ below, I hereby acknowledge that I have read this Policy, understand its content, and consent to the intended use of my personal information by Achiko as elaborated in this Policy. In addition, I confirm that all Data that I have provided or will provide to Achiko is true and accurate.