JTB PDPL Privacy Policy (Indonesia)
This Privacy Policy (“Policy”) sets out the basis in which PT. JTB
Indonesia (“we”, “us”, or “our”) may collect, use, disclose, or
otherwise process personal data of users in accordance with the
Indonesian Personal Data Protection Law No 27 Year 2022 (“PDPL”). This
policy applies to personal data in our possession or under our control,
including personal data in the possession of organisations which we have
engaged to collect, use, disclose, or process personal data for our
purposes.
Personal Data
As used in this Policy: “customer” means an individual who (a) has
contacted us through any means to find out more about any goods or
services we provide, or (b) may, or has, entered into a contract with us
for the supply of any goods or services by us; and “personal data” means
any data related to identified or identifiable individuals, separately
or in combination with other information, directly or indirectly,
through an electronic or non-electronic system.
Depending on the nature of your interaction with us, some examples of
personal data which we may collect from you include(s) name, residential
address, email address, and telephone number; this list is
non-exhaustive.
Other terms used in this Policy shall have the meanings given to them
in the PDPL (where the context so permits).
Collection, Use, and Disclosure of Personal
Data
1. We generally do not collect your personal data unless:-
It is provided to us voluntarily by you directly or via a third
party who has been duly authorised by you to disclose your personal data
to us (your “authorised representative”) after:
you (or your authorised representative) have been notified of the
purposes for which the data is collected, and
(ii) you (or your authorised representative) have provided
written consent to the collection and usage of your personal data for
those purposes, or
Collection and use of personal data without consent is permitted
or required by the PDPL or other laws. We shall seek your consent before
collecting any additional personal data and before using your personal
data for a purpose which has not been notified to you (except where
permitted or authorised by law).
2. We may collect and use your personal data for any or all of the
following purposes:-
Operating our website and/or its subdomains (“website”);
Performing our statutory functions and administering our
activities;
Communicating with our members and customers;
Updating your personal and contact information;
Performing obligations in the course of or in connection with our
provisions of the goods and/or services requested by you;
Verifying your identity;
Responding to, handling, and processing queries, requests,
applications, complaints, and feedback from you;
Managing your relationship with us;
Processing payment or credit transactions;
Complying with any applicable laws, regulations, codes of
practice, guidelines, or rules, or to assist in law enforcement and
investigations conducted by any governmental and/or regulatory
authority;
Statistical, analysis, planning and reporting,
Any other purposes for which you have provided the information;
and
Any other incidental purposes related to or in connection with
the above.
Marketing Purposes
3. This Policy does not apply to aggregated information which
summarises statistical information about groups of members, and which
does not include name, contact information, or any other information
that would allow any particular individual to be identified.
4. We may disclose your personal data:-
Where necessary to enforce the Terms of Use;
Where such disclosure is required for performing obligations in
the course of or in connection with our provisions of the goods and
services requested by you;
To third party service providers, agents, and other organisations
we have engaged to perform any of the functions with reference to the
above-mentioned purposes;
If required by law or in the good faith belief that such action
is necessary to:
Conform to the edicts of the law or comply with legal processes
served on us or the Website;
Protect and defend our rights or property; and
Act under exigent circumstances to protect the personal safety of
users of the Website; or
Where your consent has been obtained for disclosure.
5. Where your use of the Website is concerned, you acknowledge and
accept that certain functions, when activated or used by you, will
operate to send or display information about yourself, including but not
limited to, your personal data to certain third parties, and you agree
to the sharing of such information with these third parties. You
acknowledge and agree that we shall not be held responsible or
accountable for any loss, injury, or damage sustained by you for sharing
the aforesaid information arising out of your activation or use of such
features on the Website.
Withdrawing Your Consent
The consent that you provide for the collection, use, and
disclosure of your personal data will remain valid until such time it is
being withdrawn by you in writing. You may withdraw consent and request
us to stop collecting, using, and/or disclosing your personal data for
any or all of the purposes listed above by submitting your request in
writing or via email to our Data Protection Officer at the contact
details provided below.
Upon receipt of your written request to withdraw your consent, we
may require reasonable time (depending on the complexity of the request
and its impact on our relationship with you) for your request to be
processed and for us to notify you of the consequences of us acceding to
the same, including any legal consequences which may affect your rights
and liabilities to us. In general, we shall seek to process your request
within 10 (ten) business days of receiving it.
Whilst we respect to your decision to withdraw your consent
please note that depending on the nature and scope of your request, we
may not be in a position to continue providing our goods or services to
you and we shall, in such circumstances, notify you before completing
the processing of your request. Should you decide to cancel your
withdrawal of consent, please inform us in writing in the manner
described in Clause 1 above.
Please note that withdrawing consent does not affect our right to
continue to collect, use, and disclosure personal data where such
collection, use, and disclosure without consent is permitted or required
under applicable laws.
Access to and Correction of Personal
Data
If you wish to make an access request for access to a copy of the
personal data which we hold about you or information about the ways in
which we use or disclose your personal data OR a correction request to
rectify or update any of your personal data which we hold about you, you
may submit your request in writing or via email to our Data Protection
Officer at the contact details provided below.
We will respond to your request as soon as reasonably possible.
Generally, our response will be within thirty (30) business days. Should
we not be able to respond to your request within that given time period
after receiving your request, we will inform you in writing within
thirty (30) business days of the time by which we will be able to
respond to your request. If we are unable to provide you with any
personal data or to make a correction requested by you, we shall
generally inform you of the reasons why we are unable to do so (except
where we are not required to do so under the PDPL).
Protection of Personal Data
To safeguard your personal data from unauthorised access,
collection, use, disclosure, copying, modification, disposal or similar
risks, we have introduced appropriate administrative, physical, and
technical measures.
You should be aware, however, that no method of transmission over
the Internet or method of electronic storage is completely secure. While
security cannot be guaranteed, we strive to protect the security of your
information and are constantly reviewing and enhancing our information
security measures.
Accuracy of Personal Data
We generally rely on personal data provided by you (or your
authorised representative). In order to ensure that your personal data
is current, complete, and accurate, please update us if there are
changes to your personal data by informing our Data Protection Officer
in writing or via email at the contact details provided below.
Retention of Personal Data
We may retain your personal data for as long as it is necessary
to fulfil the purpose for which it was collected, or as required or
permitted by applicable laws.
We will cease to retain your personal data, or remove the means
by which the data can be associated with you, as soon as it is
reasonable to assume that such retention no longer serves the purpose
for which the personal data was collected, and is no longer necessary
for legal or business purposes.
Transfers of Personal Data Outside of
Indonesia
If there are transfers of personal data to countries outside of
Indonesia, we will obtain your consent for the transfer to be made and
we will take appropriate steps to ensure that your personal data
continues to receive a standard of protection that is at least
comparable to that provided under the PDPL.
Use of Cookies
The Website may place and access certain cookies on your computer
and/or any other electronic device used to access the Website. We use
cookies to improve your experience using the Website and to improve the
efficacy of our Services. We have carefully chosen these cookies and had
taken steps to ensure that your privacy policy is protected and
respected at all times.
Users of the Website are advised that if they wish to deny the
use and saving of cookies from this Website onto their computers and/or
other electronic devices, they should take the necessary steps within
their internet browsers’ security settings to block all cookies from
this Website.
You can choose to delete the cookies at any time. However, you
may lose any information that enables you to access the Website more
quickly and efficiently including but not limited to personalisation
settings.
External Websites
The Website contains links to external websites. We make no
representations as to the quality, suitability, functionality or
legality of the material on external websites that are linked to, or to
and goods and services available from, such websites. The material is
only provided for your interest and convenience. We do not monitor or
investigate such external websites and we accept no responsibility or
liability for any loss arising from the content or accuracy of the
material and any opinion expressed in the material should not be taken
as our endorsement, recommendation, or opinion. This Policy does not
extend to your use of such external websites. You are advised to read
the privacy policy or statement of such external websites before using
them.
Data Protection Officer
You may contact our Data Protection Officer if you have any enquiries
or feedback on our personal data protection policies and procedures, or
if you wish to make any request, in the following manner:
Contact Number: +62 361 708761
Email Address: privacy.id@jtbap.com
Address: Jalan By Pass Ngurah Rai No 88, Kelan Abian – Tuban – Bali -
Indonesia
Effect of Policy and Changes to Policy
This Policy applies in conjunction with any other notices,
contractual clauses, and consent clauses that apply in relation to the
collection, use, and disclosure of your personal data by us.
We may revise this Policy from time to time without any prior
notice. You may determine if such revision has taken place by referring
to the date on which this Policy was last updated. Your continued use of
our services constitutes your acknowledgement and acceptance of such
changes.
Information for EU Citizens
This part of the document integrates with and supplements with the
information contained in the rest of the policy and is provided by the
business running this Site and, if the case may be, its parent,
subsidiaries and affiliates (for the purposes of this section referred
to collectively as “we”, “us”, and “our”.
JTB GDPR Privacy Policy
The provisions contained in this section apply to all EU
citizen users, according to the GDPR. Users are referred to below,
simply as “you”, “your”, and “yours”), and for such consumers, these
provisions supersede any possibility divergent or conflicting provisions
containing in the privacy policy.
The protection of your personal data is of great importance to JTB
(“PT.JTB Indonesia”). This Privacy Policy therefore intends to inform
you about how the JTB (“PT.JTB Indonesia”), whose entities may act as
data controllers or processors, collect and processes your personal data
that you submit or disclose to us, in the case where the General Data
Protection Regulation (“GDPR”) applies to such collection or
processing.
JTB (“PT.JTB Indonesia”) routinely collects, uses, stores and
transfers a variety of data, including Personal Data. JTB Group is
committed to ensure the privacy of Personal Data throughout its global
business, and make sure its employees and business partners also take
the necessary measures to protect Personal Data.
This Privacy Policy sets out the basis on which any personal data we
collect from you, or that you provide to us, will be processed by us.
Our Privacy Policy applies to you in the case where the GDPR applies to
such collection or processing and is available on our website and
through other channels. In all your dealings with us you must ensure
that others you may represent are aware of the content of our Privacy
Policy and consent to you on their behalf.
We encourage you to read this Privacy Policy carefully. If you do not
wish your personal data to be used by us as set out in this Privacy
Policy, please do not provide us with your personal data. Please note
that in such a case, we may not be able to provide you with our
services, and your customer experience may be impacted.
1. Your Personal Data
This refers to a combination of personal data such as your name,
address, telephone number, email address, travel preference and special
needs/disabilities/dietary requirements that you supply us or is
supplied to us, including your social preference, activities and any
information about other persons you represent such as those on your
booking. Your personal data is collected when you contact us, make a
booking, use our website(s)/apps, link to or from our website(s)/apps,
connect with us via social media and any other engagement we or our
business partner have with you.
2. Processing of Your Personal Data
Data processes
We may collect and process your personal data for the purposes set
out below and disclose your personal data to the JTB (“PT.JTB
Indonesia”) companies for business purposes and also to our service
providers who act as ‘controller’ or ‘processor’ on our behalf. These
purposes include:
Fulfilling the contract with you and legal obligations (Articles
6(1)(b) and (c) of the GDPR: In order for you to travel abroad, it may
be mandatory as required by government authorities at the point of
departure and/or destination to disclose and process your personal data
for immigration, border control and/or any other purposes. Also we need
to provide airlines/accommodation providers with your name, passport
number, contact details, and other related information in accordance
with their terms and conditions. If you do not provide us with this
personal data, we might not be able to offer our services to
you.
Fulfilling your and our legitimate interests (Article 6(1)(f) of
the GDPR): Where it is in both your and our benefit that we further
process your personal data as part of our business administration,
maintaining service quality, customer care, business management, risk
assessment/management, security, and operation purposes.
Consent: For marketing purposes and other similar data processes
that may require your authorization for their processing (Article
6(1)(a) of the GDPR). We will usually inform you before collecting your
data if we intend to use your data for such purposes or if we intend to
disclose your personal data to any third party for such purposes. You
can exercise your right to prevent such processing by checking certain
boxes on the forms we used to collect your data.
Explicit consent (Article 9(2)(a) of the GDPR): Information such
as health or religion may be considered ‘sensitive personal data’ under
the GDPR. This personal data might include information necessary to
arrange bookings and travel plans, including your allergies,
disabilities, and other relevant health information. We collect it to
provide you with our services, cater to your needs or act in your
interest, and we are only prepared to accept sensitive personal data on
the condition that we have your positive consent.
We will process your data for as long as possible in order to fulfil
our service to you and comply with the applicable fiscal, tax,
securities and commercial law regulations on retention of business and
financial documentation.
Children
Our products and services are intended for adult customers. However,
we may knowingly collect and process personal data on children under
seventeen (17). On these occasions, we will take account of this event
when processing the personal data of children and implementing the legal
basis for such processing. For example, where the processing of personal
data of children is based on their consent such as the processing of
his/her sensitive personal data, we will seek the consent of parents,
tutors, or other adults holding parental responsibility over children,
if required under the GDPR.
Links to other sites
We may propose hypertext links from our websites to third-party
websites or Internet sources. We do not control and cannot be held
liable for third parties’ privacy practices and content. Please read
carefully their privacy policies to find out how they collect and
process your personal data.
Data transfers
JTB Group
When we process your personal data, we will store it on our systems
located within the European Economic Area (EEA), which comprises the
Member States of the EU, Norway, Iceland and Liechtenstein, as well as
outside the EEA. In the event of a merger, reorganization, acquisition,
joint venture, assignment, spin-off, transfer, or sale or disposition of
all or any portion of our business, including in connection with any
bankruptcy or similar proceedings, we may transfer any and all personal
data to the relevant third party.
Your data may also be processed by staff operating outside the EEA
who work for us or for one of our suppliers (e.g., travel guides,
transportation services). Such staff may be engaged in, among other
things, the provision of support services.
Service providers
For the purpose of providing you with our services, including your
booking of flight, hotel, security, incident/accident management etc.,
we may disclose and process your personal data outside of the EEA
countries. In order for you to travel abroad, it may be mandatory as
required by government authorities at the point of departure and/or
destination to disclose and process your data for immigration, border
control and/or any other purposes. Also we need to provide
airlines/accommodation providers with your name, passport number,
contact detail, etc. in accordance with their terms and conditions.
Legal compliance and security
It may be necessary for us – by law, legal process, litigation,
and/or requests from public and governmental authorities within or
outside your country of residence – to disclose your personal data. We
may also disclose your personal data if we determine that, due to
purposes of national security, law enforcement, or other issues of
public importance, the disclosure is necessary or appropriate.
We may also disclose your personal data if we determine in good faith
that disclosure is reasonably necessary to protect our rights and pursue
available remedies, enforce our terms and conditions, investigate fraud,
or protect our operations or users.
Safeguards to protect your personal data
Where we share your data with a data processor, we will put the
appropriate legal framework in place in order to cover such transfer and
processing (Articles 26, 28 and 29). Furthermore, where we transfer your
data from EEA to any entity outside the EEA, we will put appropriate
legal frameworks in place, notably Binding Corporate Rules (Article 47
GDPR), controller-to-controller (2004/915/EC) and
controller-to-processor (2010/87/EU) Standard Contract Clauses approved
by the European Commission, in order to cover such transfers (Articles
44 ff. GDPR), or we will share your data based on rules of the GDPR.
By submitting your personal data, you agree to this transfer, storing
or processing. We will take all steps reasonably necessary to ensure
that your data is treated securely and in accordance with this Privacy
Policy, in particular, by adopting Standard Contract Clauses (for
transfers among certain JTB companies and with third-parties) where
possible.
3. Our Records of Data Processes
We handle records of all processing of personal data in accordance
with the obligations established by the GDPR (Article 30), both where we
might act as a controller or as a processor. In these records, we
reflect all the information necessary in order to comply with the GDPR
and cooperate with the supervisory authorities as required (Article
31).
4. Security Measures
We process your personal data in a manner that ensures their
appropriate security, including protection against unauthorised or
unlawful processing, accidental loss, destruction or damage. We use
appropriate technical or organisational measures to achieve this level
of protection (Article 25(1) and 32 GDPR).
We will retain your personal information for as long as it is necessary
to fulfil the purposes outlined in this Privacy Policy, unless a longer
retention period is required or permitted by law.
5. Notification of Data Breaches to the Competent Supervisory
Authorities
In case of breach of security leading to the accidental or unlawful
destruction, loss, alteration, unauthorised disclosure of, or access to,
personal data transmitted, stored or otherwise processed, we have the
mechanisms and policies in place in order to identify it and assess it
promptly. Depending on the outcome of our assessment, we will make the
requisite notifications to the supervisory authorities and
communications to the affected data subjects, which might include you
(Articles 33 and 34 GDPR).
6. Processing Likely to Result in High Risk to your Rights
and Freedoms
We have mechanisms and policies in place in order to identify data
processing activities that may result in high risk to your rights and
freedoms (Article 35 of the GDPR). If any such data processing activity
is identified, we will assess it internally and either stop it or ensure
that the processing is compliant with the GDPR or that appropriate
technical and organisational safeguards are in place in order to proceed
with it.
In case of doubt, we will contact the competent Data Protection
Supervisory Authority in order to obtain their advice and
recommendations (Article 36 GDPR).
7. Your Rights
You have the following rights:
– Access to personal data: You have the right to be provided full
information about your personal data that we hold.
– Data correction: You have the right to require that we correct any
incorrect information we hold about you.
– Data deletion: You may also have the right to ask that we delete your
personal data. Please note that certain conditions may apply to the
exercise of this right.
– Restriction on processing of personal data: You may have the right to
ask that we restrict the use of your personal data. Please note that
certain may conditions apply to the exercise of this right.
– Object to processing of personal data: You may have the right to
object to the use of your personal data by us. Please note that certain
conditions may apply to the exercise of this right.
– Portability of personal data: You may have the right to receive your
personal data in a structured and commonly used format. Please note that
certain conditions may apply to the exercise of this right.
– You also have the right to obtain from us a copy of the Binding
Corporate Rules or of any Standard Contract Clauses that we use if we
transfer your personal data outside the EEA and take such
arrangement.
To exercise your rights, or if you require further information about
how your personal data is used by us, you can contact the staff member
in charge of your travel or write to us at:
privacy.id@jtbap.com
Following is the procedure when you want to execute these
rights;
1) Upon receiving your request, we will contact you to confirm the
request is being handled, and we will indicate the reasonable timeframe
for us to respond.
2) Our special team will make an initial assessment of the request to
decide whether it is a valid request and whether confirmation of
identity is required.
3) If no further action from you is required, we will proceed with the
processing of your request.
4) At the end of our assessment and internal procedure, we will provide
a confirmation as to our compliance or processing of your request.
5) For any unfounded or excessive (e.g., further repeated) requests, we
may charge a reasonable fee based on administrative costs.
8. When you want to complain about your personal
data
We have appointed appropriate staff with management support to
oversee and ensure compliance with the GDPR. You can bring complaints in
writing by contacting the JTB Data Protection Team at
emmy_f.id@jtbap.com
You can also contact the JTB Data Protection Team members or other
employees to complain about the way we handle your personal data. The
employees to have been confronted with the complaint will inform you
about the contract details to file a complaint in accordance with the
present procedure or pass the complaint to the JTB Data Protection Team
whichever appropriate.
After receiving the complaint the Data Protection Team will send an
acknowledgement of receipt within one week to you. The confirmation may
include further questions necessary for the clarification of the issues.
The Data Protection Team or local Human Resources Department will
provide an answer to you as soon as reasonably practicable, but no later
than one month upon receiving the complaint. If, due to complexity of
the complaint, a substantive response within one month cannot be
provided, you will be notified with a reasonable estimate of the
timeframe, but not exceeding two months from the notice.
You may also raise the complaint to the relevant Data Protection
Authority or lodge a claim with a court of competent jurisdiction.
9. Changes to our Privacy Policy
We may revise or update this Privacy Policy from time to time. Any
changes we may make to our Privacy Policy in the future will be posted
on this webpage. If we make changes which we believe are significant, we
will inform you through the website to the extent possible and seek your
consent where applicable.
10. Contact
Questions, comments and requests regarding this Privacy Policy are
welcomed and should be addressed to
Jalan By Pass Ngurah Rai No.88, Kelan Abian – Tuban- Bali -
Indonesia
Email: privacy.id@jtbap.com
11. About Cookie
PT.JTB Indonesia (hereinafter “JTB”) automatically collect limited
information about your computer when you visit our site. JTB records the
IP address of visitors in the case of a problem occurring on our server,
as well as for statistical purposes. The IP address of a user may be the
same each time, or it may be different – this depends on the method of
connection i.e. dial-up or constant connection (e.g. DSL or cable
modem). In both cases, it is extremely difficult to gain personal
information from the IP address of a visitor, and we will never attempt
to find out this information from you.
JTB uses cookie information to provide better services, secure
security, analyse and distribute appropriate advertisements to
customers. If you came to our site by clicking on a link on a different
site, we will also record this information. This kind of information
helps us understand our users’ preferences and measure the effectiveness
of various advertising. It will also help us to customize the content of
our website and to improve our service. All information is collectively
integrated into our database (as opposed to being collected individually
from each user) and is used as a general overview of all our users.
Third-party companies may distribute advertisements or obtain
behavioural information for the purpose of advertising their
company.
Small data text files called “cookies” will be sent to your
computer’s hard drive. These cookies help us recognize previous visitors
and also identify the route history of users. We cannot identify any
personal information stored in these cookies, nor can we gain access to
any information stored on your hard drive. In addition, we cannot access
information from cookies sent from other websites. Information collected
will only be used as described above, and also to improve our
website.
Each user can prevent their browser from accepting new cookies,
however in this case cookies from all websites will be blocked, not only
cookies sent from JTB. As every browser is different, it is best to go
to the Help portion of the toolbar of your browser to explain how to
block cookies.
※ If you change browser, delete cookie, etc., you need to set opt-out
and opt-in again
Exhibit
ASIA/PACIFIC Companies
JTB PTE LTD / JTB Asia Pacific Headquarters
JTB PTE LTD / JTB Singapore office
JTB (Thailand) Ltd.
Japan Travel Bureau (Malaysia) Sdn. Bhd
PT. JTB Indonesia
世帝喜旅行社股份有限公司
JTB-TNT (JTB Vietnam)
JTB India Private Limited
Tour East Singapore (1996) Pte Ltd
JTB Asia Pacific Phil. Corp.
PT. Panorama JTB Tours Indonesia
BIG S’ Holiday Pte. Ltd.
JTB Oceania Pty Ltd
JTB Australia Pty Ltd
JTB New Zealand Limited