This Privacy Policy shall describe the Personal Data that We collect from You. Personal Data means the data that can be identified You personally, which contains information, including but not limited to, full name, place of birth, gender, address, ID card or passport, telephone number, blood type and email, photo, biometrics, bank account, and job information.

We collect Your Personal Data to identify You in using the Application or Service. The collection of Personal Data may be in the form when You are accessing the Application for the first time by filling out the registration data form. If You are a representative of Your company or individual, You shall be responsible for the personal data information You provided. We collect Your Personal Data as long as You use the Application or Service that is intended for You, such data collection can be done by the following activities, including but not limited to: • When You use the Application as a representative of Your company, You will fill in Your company data and information on the form page provided. Details of filling out the data form can be in the form of, such as company name, company organizational structure, job title, email, employee name (including ID card or passport number), bank account data, photo, salary nominal, and payroll period date. For each additional service We provide to You, You will be asked to submit additional data so you can take advantage of the additional service. • When You use the Application as a representative of Your company, You shall fill in Your company data and information on the form page provided. Details of filling out the data form can be in the form of, such as company name, company organizational structure, job title, email, employee name (including ID card or passport number), bank account data, photo, salary nominal, and payroll period date. For each additional Service We provide to You, You will be asked to send data so that You can take advantage of the additional Service. • Location Data Access. When You run the Application as an employee user, You will be asked to access your location approval directly. Granting Your location access depends on the Device permissions You use and agree to. You will be asked to allow Us to access Your actual location information through Your device when You want to record attendance or take advantage of other features through our application. We will collect Your location data for this purpose, including Your IP Address and GPS. To the extent that You allow access to Your location through your device, We will only use Your location data to determine Your current location for the services We provide to You, including the features that You can use while using Our application. You may choose not to grant location permissions access of Your requested via your device. You can still use Our Applications and Services, but the use of some features will be provided on a limited use basis. • Face Recognition Identification. When You run the Application as an employee user, to the extent required by Your Company to provide services in connection with module attendance or absence management, where relevant, You will be asked to access a photo of Your face. Granting Your photo access depends on the Device permissions You use and agree to. We will collect data photos of Your face which are intended to record your attendance data and will match such data with your previously stored data to verify your presence. You may choose not to grant access to the photo of Your face through Your device or Your file and can still use the Application and Services, but this may affect the recording of Your presence in the company. In addition, We also collect general information about the use of Our system through log files to monitor performance and improve the performance and/or usability of the application.

Your data including Personal Data will be used for the provision of Services or as long as You use the application including when You visit our website. Where You are a user as a representative of Your company, We may use and process Your data as follows: • use, receive, store, reproduce, modify, create derivative works (such as those resulting from translations, adaptations, or other changes we make so that your content works better with our Applications or Services), and • communicate, publish, announce, perform, display and distribute such derivative works; • provide preferences for Services to be provided in the future and offer them to you for your business solution needs; • have conversations with you via email, telephone, or other communications; • administer Your account registration on the Application; • verify and analyze Service submissions; • provide information on the process and mechanism of payment through bank accounts; • provide access and facilities to the Services that You use and We agree to; • make payments to Your employees’ salaries following the salary period you have informed Us; • Notify You of Application or Service updates from time to time; • perform monitoring, analysis, and development of the Application or Service; • Offer additional services from third parties for Your needs; • offer You any updates to the Application or Services including but not limited to marketing communications, feature additions, discount offers and promotions; and • Provide continuous service support as long as You use the Application or Our Services. Where You are a user as an employee, We may use and process Your data as follows: • identify Personal Data while using the Application or Service; • provide Services for attendance, leave application, overtime, business travel, performance appraisal, or other Services provided to You; • perform direct checks on the use of the Location Access feature that You have agreed to; • make payment for Your salary according to the payment period addressed to You; • provide additional Services that You may take advantage of from time to time; • respond, approve or reject the request for submission of Services that You do in the Application; and • perform monitoring, analysis, assessment, and additional support services to You. We also process Your data when You visit Our site, if You are an unknown visitor, We link a small file, namely a cookie while You are browsing Our website or application. Cookie Terms as set out in item 9 below. In addition, if needed for legal purposes, We use and process Your data for legal purposes in accordance with applicable laws and regulations.

We need to disclose Your data in order to provide Our services to be better. The data disclosures that We can do to, as follows: • To Your Company, including members of the finance or Human Resources division for the Your Company purpose. • To Our Affiliates to develop Applications or Services. • To third parties who partner with Us in providing Services, including professional advisors, legal advisors, financial advisors, external auditors, and other consultants. • To the bank for the agreed payment or salary payment. • To the government in power or authorized institutions, including the police, manpower agencies, courts, or international government agencies, and aimed at implementing legal decisions or prevailing laws and regulations.

You may submit Us to make corrections to Your data as long as the data is in Our control. We will ask You for a detailed explanation of the reason for the correction. Subject to applicable laws, First, We will verify at Your request. We shall refuse to correct data as long as We collect Your data from references from third parties and Your habits in the application or while using our services.

We store Your Data for as long as You use and utilize Our Application or Services. Data storage is intended for You to take advantage of the Application and Services. Our Applications and Services are available as solutions for human resource systems (“HR System“). A company’s HR system may, for example, store Data related to job applications, payroll records, training history, compensation history, retirement plans, health information, and so on. Over time, a company’s HR system will collect a large number of records, many of which contain personal information related to individuals. We may delete Your Data including Personal Data when You stop using Our Application or Services. You may request (i) a copy of your Data to be returned to you and/or (ii) to delete Your Data, no later than 30 calendar days after the termination date of the Service. After the expiration of 30 calendar days, we may permanently delete your Data from our system to comply and to the extend permissible under the applicable law. You can inform Us of the requirements to submit such request by contacting Us below.

Data Storage is located and processed in Indonesia and may be processed where You are located (“Your Home Country”). We try to ensure that the data retention policy will comply with the laws of Your Home Country. Your data can be transferred, processed, and used in other countries but You can still use, access, and utilize Our Applications or Services. We will ensure to always comply with the regulations on the use of Personal Data in your Home Country including our Affiliates in other countries.

To the extent that We receive information in connection with third-party services, We may use this information for the purposes specified in the agreement, such as to provide access to third-party services. Applications or Services may provide you with the ability to connect with third-party sites, services, and applications, which allow third parties to collect or share information about Your Data and will refer to the privacy policies of such third parties. All third-party connections are beyond Our control and We ask you to check the privacy policies and terms of use of third-party connections before using them or providing Your Personal Data to them. To the extent that You agree to the terms and conditions of third-party Services accessing, updating, or modifying Your data, You agree that We will allow and/or facilitate such access, updates and modifications. In connection with the use of the Application or Service, We may be able to send You service announcements, administrative messages, and other information. You can choose from several of these communications.

A cookie is a small file that is transferred to Your computer in order to allow Our website to identify You and authenticate Your access to some sections of Our website. If you do not wish to receive cookies You may set Your web browser not to accept them. This may limit Your ability to access some sections of the website. To learn more about disabling cookies, please visit the site below for your specific web browser: – Firefox – Chrome – Internet Explorer – Safari

As long as You use Our Applications and Services, and if You always provide Your information and Personal Data, You acknowledge that You have read and understand and agree to submit to the terms of this Privacy Policy. Including those of You who act as representatives of Your Company, You represent that You are the party entitled to represent them and have obtained approval from Your employees to provide data, including Personal Data for your business interests.

We always try to provide and have implemented an adequate security system to safeguard Your Personal Data, including the placement of data on Our servers. We will maintain the security of Your data and prevent unauthorized access, collection, processing, use, disclosure, copying, and modification. However, We still recommend that you always pay attention and be careful in providing Your Personal Data while using Our Application or Service. You are responsible for Your mistakes in maintaining Your Personal Data which are not caused by negligence or beyond our control. No technology is completely secure in transmission or storage and You should be careful with the information you transmit.