Orratto Privacy Policy

1.

Collection and Use of Personal Data

1.

Collection of Personal Data

• “Personal Data” data about an identified or identifiable individual individually or in combination with other information either directly or indirectly through electronic or non-electronic systems, as defined in the Personal Data Protection Act.
• We collect information and User Personal Data for the purpose of processing User transactions, managing and expediting the process of using the Site, as well as other purposes as long as permitted by applicable laws and regulations. The User data collected is when the User:
  a.

  Create or manage a orratto account, including among others: (a) your first and last name, (b) your home address, (c) your date of birth, (d) your email address, and, only if it matches (e) username and your password, and (f) contract preferences, (g) device identifiers, (h) Internet Protocol (IP address) addresses, (i) location information, (j) credit/debit card information, (k) profile information where such contact is via social media and (l) other information as may be reasonably required by us.
  b.

  Contacting orratto, including through customer service;
  c.

  Using the services and features available on the Site;
  d.

  Fill in payment data when Users carry out payment transaction activities through the Site, including but not limited to bank account data; and/or
  e.

  Using features that require access permission to the User's device.
• In certain jurisdictions, We may ask for a government-issued identity including when creating a wireless account and activating your device, for the purpose of extending commercial purposes, administering services as required by applicable laws and regulations.

2.

Personal Data and Information Collected Every Time You Use or Visit Our Site

• We use trusted services to collect information and User Personal Data when using orratto services. We may collect certain technical data in connection with your use of orratto services such as: Internet Protocol address (IP address), search site (web browser), previously or subsequently viewed site (web) page information, duration of each visit/session, number of clicks on when accessing the site, the identity of the internet device or media access control address, and information regarding the manufacturer, model and operating system of the device you use to access Our Site.
• When you use or visit Our Site, certain information may also be collected automatically using cookies. Cookies are small data files stored on your computer or mobile device. We use cookies to track User activity with the aim of improving user interface interaction and User experience and remembering your browsing preferences on Our Site. Most mobile devices and internet browsers support the use of cookies; however, you can adjust the settings on your mobile device or internet browser to reject certain types of cookies or specific cookies. Your mobile device and/or browser may also allow you to delete any cookies that have been previously stored. However, it may affect the functions available on Our Site.
• Every time you use and access the Site via a mobile device, We will track and collect your geographic location information in real time. In some cases, you will be asked or required to activate the Global Positioning System (GPS) on your mobile device to enable us to provide you with a better experience in using the Site. You can temporarily disable geographic location tracking information on your mobile device. However, this may affect the functions available on the Site.

3.

Information Collected From Third Parties

• We may also collect information and your Personal Data from third parties (including, but not limited to affiliates, agents, partners, law enforcement and regulatory authorities, technology service providers such as hosting sites or with whom we cooperate). In such cases, We will only collect Your Personal Data for or in connection with the purposes involving such third parties or the purposes of Our cooperation with such third parties (depending on the situation).
• orratto may provide/disclose information and certain User Personal Data to third parties to provide or improve our products and services, including but not limited to delivering products at your request, or to help market orratto to consumers, provision of payment system services, system services delivery for transactions between Online Stores and Customers, orratto Market Service needs and other related service needs. When we make such disclosures, we ask the third party to carry it out in accordance with applicable law. If you agree to this service, your account will be governed by orratto and your respective carrier's privacy policy. Your acceptance or agreement to the Privacy Policy does not include your acceptance or agreement to other privacy policies unless expressly stated otherwise in this Privacy Policy. We require that each entity that operates third party services has the lawful right to collect, use and share your information before providing any information to us.

2.

Use of Personal Data

1. Process all forms of requests, activities or transactions made by Users through the Site, including to process, manage or verify your identity.
2. Providing of features to provide, create, maintain and improve our products and services, including but not limited to:
   a.

   Offer, obtain, provide, or facilitate other services or products through the Site;
   b.

   Fulfill and validate your purchases, orders and/or requests;
   c.

   Process payments from You, including authorization and processing of online payments, credit/debit card transactions, and sending you receipts;
   d.

   Perform internal activities necessary to provide services on the Site, such as troubleshooting software problems, bugs, operational issues, conducting data analysis, testing, and research, and to monitor and analyze usage trends and activities.
   e.

   Helping Users when communicating with our customer service, including but not limited to:
   1. Checking and solving User problems;
   2. Respond and direct User questions, requests, and feedback to customer service officers to resolve User problems; And
   3. Monitor and improve customer service response and performance.
3. Contacting Users via email, telephone, etc., to assist and/or complete the transaction process or problem resolution process.
4. Inform Users regarding products, services, promotions, studies, surveys, news, latest developments, events and other information, both through the Site and through other media.
5. Conduct market research or surveys, internal marketing analysis, customer profile activities, analysis of customer patterns and choices, analysis of usage trends and activities in relation to the Site and/or services and demographics of Our Users (based on anonymization).
6. Administrative activities and internal updates, such as audits, data analysis, record keeping, contact lists, risk management, security, etc.
7. Our storage, backup hosting (whether for disaster recovery or otherwise) of your information and Personal Data, whether within or outside your country, and you agree and consent to Us using and processing your information and Personal Data for the purposes as identified in this Privacy Policy.
8. Investigate suspected cheating, fraud, forgery or other violations of any law, rule or regulation, Site rules or policies, or third party rights, or to investigate any suspected behavior that We consider inappropriate.
9. We will also use information and Personal Data to provide you with access to and improve our services; for example, to make our platform interface easier to use. We may also use your information and Personal Data to personalize services for you and to provide advertising or marketing materials to you.
10. We will also use information and Personal Data to facilitate business/corporate transactions (which may be but are not limited to mergers, acquisitions, or asset sales) involving us and/or our affiliates.
11. In certain circumstances, We may need to use or disclose User information and Personal Data for law enforcement purposes or to fulfill applicable legal and regulatory requirements, including in the event of a dispute or legal process involving the User and Us.

3.

Disclosure of Personal Data

1. We will only disclose information or Personal Data provided to orratto as needed for the implementation of Our services that are used by Users. We basically act as a SAAS / solution for sellers ("Merchant") so that User Personal Data held by us is also disclosed to and can be accessed and stored by Merchants using orratto with whom you make transactions.
2. Apart from the Merchants who use orratto with whom you make transactions, we may also disclose or share your information and Personal Data in connection with the following matters:
   a.

   It is necessary to disclose data to partners or third parties who collaborate with us in providing services on the Site and processing all forms of activity on the Site, including transaction processing, payment verification, and other activities related to services on the Site.
   b.

   We may disclose information and User Personal Data to our subsidiaries or affiliates to help provide services or carry out data processing for the development of services on the Site. In the event that another entity acquires us, we will disclose and transfer the information and personal data that we collect to that entity.
   c.

   Required to be disclosed based on applicable laws and regulations, such as in response to a court order. To the extent permitted by law, if there is a request from law enforcement officials or other public officials or if we feel that such disclosure could prevent a criminal investigation, facilitate an investigation related to public safety, protect the security or integrity of our services, or enable us to take preventive measures for possible liabilities that may arise.
3. The data we share will be analyzed and we will try to limit the information based on what really suits the needs of the Service. If possible, we will try to disguise or anonymize the data before providing it to third parties so that privacy and security are maintained.
4. When you give permission to a third party to use your orratto Account to access or use services provided by that third party, the use of user information and Personal Data by the third party is subject to the terms and conditions and/or privacy policy of each third party.
5. We may also disclose your information and Personal Data if we consider that such disclosure is necessary for the purposes of national security, law enforcement or other matters of public interest. We may also disclose your information and Personal Data if we consider that disclosure is necessary to enforce the Terms and Conditions or protect our operational activities, service delivery or Users. This disclosure may include providing information to public or government authorities. In addition, in the event of a reorganization, merger, or sale, We may transfer any and all information and Personal Data that We collect to the relevant third party.

4.

Service Provider

• orratto shares information and User Personal Data with companies that provide services such as information processing, adding credit, fulfilling customer orders, shipping products to you, managing and improving customer data, providing customer service, assessing your interest in our products and services, and conducting research. customer or satisfaction surveys. These companies are obliged to protect your information and Personal Data and can be found wherever orratto operates.

5.

Personal Data Storage

1. Your Personal Data will only be stored as long as necessary to fulfill the purpose for which it was collected, or as long as such storage is required or permitted by applicable laws and regulations. To determine the appropriate retention period, We consider the amount, nature and sensitivity of your personal data, the potential risk of harm from use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means and the legal requirements required. apply. We will also retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies. We will stop storing Personal Data, or delete the purpose of associating the Personal Data with you as an individual, as soon as it is deemed that the purpose for which the Personal Data was collected is no longer necessary to store the Personal Data and the storage is no longer necessary for business or legal purposes. Your Personal Data can be deleted based on your request provided that the data on the back-up server is still stored by orratto.
2. Please note that there is still a possibility that some of your information and Personal Data is stored by other parties in certain ways. Information conveyed through communications between Users conducted other than through use of the Site (such as through telephone calls, SMS, mobile messages or other means of communication) may also be stored in several ways. We do not allow and encourage the storage of Personal Data in this way and we are not responsible to you for this. We will not be responsible for the storage of your Personal Data. You agree to indemnify, defend and hold us, our officers, directors, employees, agents, partners and affiliates harmless from and against any and all claims, losses, liabilities, costs, damages and costs (including but not limited to costs legal and full compensation costs) resulting directly or indirectly from any unauthorized storage of your Personal Data.

6.

Personal Data Security

1. We will try to use strict procedures, standards and security settings to protect your Personal Data that is in our possession or under our control. After receiving your Personal Data, We will make the necessary security arrangements to protect the Personal Data as is appropriate and appropriate to the existing situation, for example, We protect your Personal Data by using encryption. When disclosing or transferring your Personal Data over the internet, We will use our best efforts to protect and secure your Personal Data from access, collection, use or disclosure by unauthorized persons and from unlawful processing, accidental loss, destruction and damage or similar risks. However, by agreeing to this Privacy Policy, you agree that no data transmission over the internet can be guaranteed to be completely secure and you acknowledge that you submit information over the internet at your own risk and discretion. Although we will do our best to protect your Personal Data, you acknowledge that we cannot guarantee the integrity and accuracy of any Personal Data that you transmit via the Internet, or guarantee that such Personal Data will not be intercepted, accessed, disclosed, altered or destroyed by unauthorized third parties, due to factors beyond our control. You are responsible for safeguarding your account details including username and password and not providing them to unauthorized third parties. We have no obligation to cover misuse of usernames, passwords or OTPs except as stated in each of the Terms and Conditions on our Site. You must also always maintain and be responsible for the security of the devices you use.
2. We design, build and operate our system to ensure that any information or documents uploaded and sent by users to our services will be stored safely and sent confidentially using security standards in the electronic information industry.
3. All User data is stored using trusted services.
4. Personal Data collected by Us is stored in the territory of the Unitary State of the Republic of Indonesia and will be available as long as the User is a orratto Account User as required by the Terms and Conditions and applicable Laws and Regulations regarding the storage of Personal Data.

7.

Compliance with the provisions of Information and Electronic Transactions, and Protection of Personal Data

1. By using orratto services, Users agree to handle and manage Information Collection, Information Use, Information Sharing in accordance with applicable laws and regulations regarding Information and Electronic Transactions, and Personal Data Protection (including but not limited to ITE Regulations). By registering with orratto, all Users give consent for User's information and Personal Data to be handled in various ways as stated in this Privacy Policy, and We guarantee that the information and Personal Data provided will be handled in good faith and only for orratto service purposes. in accordance with applicable laws and regulations.
2. If in the future, all or part of this Privacy Policy conflicts or violates applicable laws or regulations, then we will adjust the part of the Privacy Policy that is in conflict or violates to fulfill compliance based on applicable laws and regulations.

8.

User Rights and Consent

1. You have the right to make changes, updates, additions or corrections to your Personal Data. In addition, you can also gain access to your Personal Data through the account that you register on the Site. However, please note that your Personal Data may be stored in our backup server for some time. In addition, you cannot delete information related to previous transactions when we track transaction history.
2. You also have the right to request access, request a copy of your Personal Data through the account that you registered on our site. We may charge a small fee (an amount as permitted under applicable law) to cover administrative costs required in processing your request to access your Personal Data. Nevertheless, We reserve the right to rely on any legal exceptions and/or exceptions to collect, use and disclose Your Personal Data.

9.

Collection and Use of Non-Personal Data Information

10.

Applicable Law

11.

Questions, Complaints and Contacts