PT SAIC Motor Indonesia , as the controller of your personal data, is committed to take technical and management measures to protect your privacy. This privacy policy is to help you better understand how we collect, use and disclose your personal information and to tell you about how to use your privacy rights. Our privacy practices comply with local privacy protection act. We will always reserve the right to modify this privacy policy.

Definitions

We (referred to as either "the Company", "Us" or "Our" in this Agreement) refers to (company name) You refers to any individual accessing or using our service, which is the data subject. Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the door status of your vehicle). Personal Data is any information that relates to an identified or identifiable individual. ISMART service refers to the online functions provided by us on head unit and mobile APP Service Provider refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of us, to perform services related to the Service or to assist us in analyzing how the Service is used.

What personal information we collect

Product and service activations

Our products and services may require electronic activation, where your device and application type, as well as unique device, application, network and subscription identifiers are sent to us.

Usage data of products and services

When you access our ISMART services online, our web servers will automatically create records of your visit. These records typically include IP-address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language and other such information. Our applications may contact our servers periodically, for example to check for updates or to send us information relating to service usage. Additionally, we may invite you to join voluntary product and service improvement or research programs where detailed information is collected. See Supplements to this Policy for more details. Vehicle Usage data is collected automatically during driving when the ISMART service is used, usage data include but not limit to: • Door status
• Windows status
• Trunk status
• Remaining mileage
• Total mileage
• Tire pressure
• Battery voltage
• Battery current
• Engine status
• EPS status
• Handbrake status
• Airbag status
• Speed

Information you provide us with

When you create an ISMART account, make a purchase, request services, participate in research or campaigns or otherwise interact with us, we may ask for your personal information for identification. We may also maintain records of your consents, preferences and settings related to driving. The personal information we collected including but not limited to: • Name
• Gender
• Date of birth
• City
• Emergency contact
• Email address
• Mobile number
• Password
• VIN number
• GPS location
• Destination
• Itinerary

Your transactions with us

We maintain records of your purchases, downloads, the content you have provided us with, your requests, agreements between you and us, the products and services provided to you, payment and delivery details, your contacts and communications and other interactions with us. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points.

Positioning and Location data

Location-based services establish location through the use of satellite, mobile, Wi-Fi, Bluetooth Low Energy (“BLE”) or other network based positioning methods. These technologies may involve exchanging your location data and unique device and mobile, Wi-Fi, Bluetooth, or other network related identifiers with us. Our products may operate on multiple device platforms, applications and services which may also collect your location data. We do not use this information to identify you personally without your consent. When you use our location based services and features, for example location based search, navigation and routing, or request for map data, your location data is sent to us to serve you with the right content.

Why we collect your information

We only collect minimum necessary personal information required for processing the functions of ISMART service. We may use your personal information for one or more purpose below including but not limited to: • To provide and maintain one or more of our functions
• To improve our product and services
• To contact you: for example, to inform you that our services have changed or to send you critical alerts and other such notices relating to our products and/or services and to contact you for customer care related purposes. Besides, we may also use your personal information to respond to your privacy complaint or feedback.
• Marketing activities: We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed.
• Any purpose you have consent to

Transfer and disclosure

We may share your personal information under circumstances below including but not limited to: • Affiliates inside the Group We have affiliates overseas to provide technical maintenance service for ISMART, they will be granted the privileges to access the server inside your Country in order to debugging when error occurs. The privileges will be strictly managed, and the maintenance team will have a periodic training on privacy protection.
• Third party service provider of ISMART We will disclose your personal information (e.g. GPS location) to third party service provider (e.g. map service provider, the map service provider will also deploy their service inside your Country). We required our third party service provider to comply with applicable laws with regard to collecting and processing those data.
• We may conduct joint marketing and other communications with our partners, for example your mobile operator. To avoid duplicate or unnecessary communications and to tailor the message to you we may need to match information that we have collected with information that the partner has collected where this is permitted by law.
• Mergers and Acquisitions: If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.

Marketing

You will receive advertisement while using ISMART service. We will ask for your consent before we send you the advertisement. We will not create any personas for marketing purposes, which means the advertisement we sent is not oriented.

Children’s privacy

Our service does not address anyone under the age of 13, so we do not knowingly collect information of children without the consent of their parents or guardians. We will publish safety guidelines for using internet services in our websites. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

What technical measures we take to protect your personal information

• Our technical maintenance team is well trained to monitor the data transmission exception. Abnormal data transmission will be detected before it had a huge impact on data subject.
• Your data will be stored in public cloud and the server is inside your Country, we choose Amazon web service as our cloud service provider where AWS can guarantee the cloud security the services they provide are in compliance with local privacy protection act.
• The communication inside ISMART system (including the mobile app, entertainment system on head unit and backend server) is encrypted to protect personal data during transmission.

How to contact us

Privacy related queries, complaints or feedback are welcomed can be completed by email or phone call. You will have privacy rights. Your rights regarding your personal information including but not limited to: • Right to know how your personal information is processed
• Right to access your personal information: You can contact us by email or telephone. We will provide you with your personal information after verify your identity.
• Right to correct your personal information: We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data. We encourage you to access your personal data through your account from time to time to ensure that it is up to date. You can contact us by email or telephone to correct your personal data as well, we will correct your personal information after verify your identity.
• Right to erase your personal information: erasing personal information can be accomplished by cancelling your account.
• Right to restrict the data processing: You can contact us by email or telephone, we will restrict processing personal information after verify your identity.
• The right to data portability: You can contact us by email or telephone, we will prepare a copy of your personal information after verify your identity, the copy will be sent to you via email within a month.
• Right to withdraw your consent: you can withdraw your consent in Settings->Privacy policy • Right to complain about our privacy measures: you can complain about our privacy measures via email or telephone. Contact Email: januar.ekasapta@mgmotor.id