In order to provide the best experience for you, and in accordance with Law of Republic Indonesia No. 27 Year 2022 Concerning Personal Data Protection and other applicable laws and regulations related with personal data protection, PT Populix Informasi Teknologi (hereinafter “Populix” or “we”) is hereby committed to protecting and respecting your privacy. For this reason, We determine this Privacy Policy to protect all personal data that is collected or transmitted through PopSurvey by Populix (“Platform”).

You or User shall mean the following: a. Any person who opens and/or accesses Platform; b. Any person who uses services and/or any features available on the Platform.

By accessing or using Our Platform, you acknowledge that each of your data is true and valid, and you have agreed to and accepted the practices set out in this Privacy Policy and agreed to comply with the Populix Terms and Conditions.

Please read the following policies carefully to understand how and why we collect, store, share and use your personal data. We will also explain your rights when you share your personal data with us.

If you disagree with the provisions of this Privacy Policy, please do not use our Platform or any other means that we have to send your personal information to us.

The term “Personal Data” means any information in our possession or control that relates directly or indirectly to an individual to the extent that the individual can be identified or are identifiable from that and other information in our possession, such as name, address, telephone number, etc, and other Personal Data as defined under the PDP Laws.

The types of Personal Data collected depend on the purpose of collection. We may process your Personal Data by way of collecting, recording, holding, storing, using and/or disclosing it.

The Personal Data and other information as provided/furnished by you to us or collected by us from you or through such other sources as may be necessary for the fulfilment of the purposes at the time it was sought or collected, may be processed for the following purposes (collectively referred to as the “Purposes”):

1. to consider and/or process your transactions with us or your transactions or communications with third parties;
2. to manage, operate, provide and/or administer your use of and/or access to our Platform (including, but not limited to your preferences), as well as your relationship and your user account with us;
3. To respond to, process, deal with or complete transactions and/or notify you of service issues and unusual account activities;
4. to protect your personal information and rights as a user of our services;
5. to identify and/or verify personal data;
6. to maintain and provide feature updates that require access to your device to ensure the smooth running of our Platform;
7. to contact you via e-mail, letter, telephone, and others, to assist and/or respond to any questions or problem-solving processes related to our services;
8. to contact you or communicate with you through telephone calls, text messages and/or fax messages, e-mail and/or postal mail, or other means for the purpose of administering and/or managing your relationship with us or your use of our services, such as but not limited to communicating administrative information to you relating to our Platform. You acknowledge and agree that such communication by us can be done by sending a letter, document, or notification to you, which may involve disclosing certain personal data about you to make such delivery and also listed on the outer cover of the envelope/postal package;
9. to track the use and activity of advertisements that are placed on the Platform and understand our user acquisition;
10. to use the information obtained from you for research, analysis, product development, and testing purposes to improve services and security on the Platform, as well as develop our new features and products;
11. to award points in a loyalty or rewards programme provided by loyalty service providers;
12. to enable audits, surveys, and analysis to, among other things, validate the size and composition of our target audience and understand their experience with us;
13. to produce statistics and research for internal reports and as required by law and/or archival requirements;
14. to prevent or investigate any fraud, unlawful activity, omission, or wrongdoing, whether related to your use of our Platform or any other matter arising from your relationship with us and if there is any suspicion regarding the preceding or not;
15. any other purposes that we will notify you of upon obtaining your consent.

The following information that You provide is processed by Us for summarizing your survey result with artificial intelligence assistance; survey title, survey questions, logic, simulations, and other study components including the survey results.

The following information that You provide is needed when and if you want to create a questionnaire using Our embedded artificial intelligence; survey topics, survey purposes, and reference analysis.

Disclosure to Third Party We will not sell, rent, transfer or disclose any of your Personal Data to any third party without your consent. However, we may disclose your Personal Data to the following third parties, for one or more of the above Purposes:
1. parties who assist us in running the Platform, solely for the purpose of running the Platform;
2. parties who assist us in providing facility and securing your payment;
3. successors in title to us;
4. any party in relation to legal proceedings or prospective legal proceedings;
5. data centres and/or servers located within or outside Republic of Indonesia for data storage purposes or otherwise;
6. government agencies, law enforcement agencies, courts, tribunals, regulatory bodies, industry regulators, ministries, and/or statutory agencies or bodies, offices or municipality in any jurisdiction, if required or authorised to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities;
7. in the event of a potential, proposed or actual sale/disposal of any of our business or interest, merger, acquisition, consolidation, re-organisation, funding exercise or asset sale relating to us, or in the event of winding-up (“Transaction”), your Personal Data may be required to be disclosed or transferred to a third party as a result of or in connection with, the Transactions.

Disclosure from Party
5.2.1 We are integrated with Google Cloud Platform to enable survey creation from Google Form. You need to sign in to your Google account in order for us to be able connect your Google Form to the Platform.
5.2.3 The Platform’s use of information received from Google Form from the User’s chosen Google account will adhere to Google API Services User Data Policy , including the Limited Use requirements.

When you use or visit our Platform, certain information may be collected automatically by using Cookies. Cookies are small text files that are stored on your device (computer, smartphone, tablet) when you visit a website. Cookies are widely used to make websites work more efficiently and to provide information to the site owners (on this Platform, Us).

In general, Our purposes of using cookies are as follows:
7.2.1 to remember your preferences and settings.
7.2.2 to analyze how you use our Platform to improve its performance and content.
7.2.3 to provide personalized content.
7.2.4 to measure the effectiveness of our marketing campaigns.
7.2.5 to Ensure the security and integrity of our Website.

Below are details of types purposes of each cookies that We use.
7.3.1 Essential Cookies: These are necessary Cookies for the operation of our Platform. These Cookies allow you to enter a secure area (“secure area”) on our Platform, use a shopping cart, or use an e-billing service.
7.3.2 Analytics / Performance Cookies: These Cookies generally allow us to recognize and count the number of visitors and see how what you are doing on Our Platform. This helps us improve the way Our Platform works, by ensuring users find what they are looking for easily on the Platform, and improve our product performance.
7.3.3 Functional Cookies: These Cookies are used to identify you when you return to our Platform. These Cookies allow us to personalize our content for you, greet you by name and remember your preferences, for example, your choice of language or region.
7.3.4 Targeting Cookies: These Cookies record your visits to our Platform, the pages you have visited, and the links you have followed. We will use this information to make Our Platform and its advertisements more relevant to your interests. We may also share this information with third parties for this purpose.

Please be aware that third parties (including, for example, advertising networks and providers of external services such as web traffic analysis services) may also use Cookies, and We have no control over these Cookies.

Where We Store Your Personal
Data All information that you provide to us is stored encrypted on our servers. Every payment transaction on the Platform will be encrypted using Secure Socket Layer (SSL) technology. In order to maintain the safety of your privacy, the SSL system that we use is a verified system that can create an encrypted link between the user’s browser session and the webserver of our Platform. SSL is the industry standard for secure web communications and is used to protect millions of online transactions.2 Content and Personal Data for Platform AI Model

We are committed to protecting the privacy and security of User Content and Personal Data. We implement robust organizational measures to ensure that the utilization of User Content for Platform AI model training adheres to the standards of data protection and information secrecy. The measures include: 

a. Anonymization and Pseudonymization
Before User Content is used for AI model training, we employ anonymization and pseudonymization techniques to remove or obfuscate personally identifiable information (PII) and highly sensitive data. This includes, but is not limited to, stripping direct identifiers, generalizing data, and using cryptographic hashing where feasible. Our goal is to minimize the risk of re-identification of individuals.
b. Data Aggregation
User Content can be used for aggregation to be used for the machine learning process. This aggregation process combines data from numerous users and surveys, further diluting any individual identifiable characteristics and focusing on collective patterns and trends.
c. Encryption
User Content, both in transit and at rest, is encrypted using industry-standard encryption protocols (e.g., TLS for transit, AES-256 for rest) to prevent unauthorized access.
d. Secure Storage
User Content used for AI model training is stored in secure, access-controlled environments with robust physical and logical security measures.
e. Regular Security Audits and Vulnerability Assessments
We regularly conduct security audits and vulnerability assessments of our systems and processes to identify and remediate potential security weaknesses.
f. Internal Policies and Training
All employees involved in data handling and AI development receive regular training on data privacy, security best practices, and our internal policies regarding the use of User Content.

The User may provide input to be processed by Platform (“Input”), and receive output generated and returned by Platform based on the Input (“Output”). When the User uses Platform, Input and Output are User’s Content. The User is solely responsible for the development, content, operation, maintenance, and use of your Content.

By using the Platform, the User grants Us and our group company a worldwide, perpetual, irrevocable, royalty-free, fully paid-up, non-exclusive, sublicensable, and transferable license to use, reproduce, distribute, prepare derivative works of, display, and perform the User Content as defined and for the purposes below, as regulated in the Platform’s privacy policy.

1. Inputs: All data, information, text, questions, answers, responses, questionnaires, and other materials submitted, uploaded, or generated by you or your respondents within the Platform, including but not limited to survey questions, answer choices, and free-text responses.
2. Outputs: All data, information, results, analyses, reports, and insights generated by the Platform based on your Inputs or the inputs of your respondents, including but not limited to survey results, statistical data, aggregated findings, and data visualizations. 

The purposes of the utilization of the User’s Content is for Platform artificial intelligence model training that is primarily to enhance the functionality, accuracy, and performance of the Platform’s features, including but not limited to:

a. improve natural language processing capabilities for survey design and analysis;
b. develop predictive analytics and insights generation;
c enhance data visualization and reporting tools;
d. automate survey creation and optimization;
e. detect patterns and trends to provide more valuable insights to users;
f. deliver the service by helping Us improve the user experience for respondents (so that questions are easier to answer);
g. for machine learning purposes (We use the data to keep training our models and to build new ones);
h. understand industry trends and help improve the completion rates on surveys/forms.