PRIVACY POLICY — PT Senmonka Milenia Bisnis (SMB)

This Privacy Policy explains how PT Senmonka Milenia Bisnis (“SMB”, “we”, “us”, “our”) collects, uses, discloses, stores, protects, and safeguards your Personal Data. This Policy complies with:

• Indonesia Personal Data Protection Law — Law No. 27 of 2022 (PDP Law)
• ISO/IEC 27001 — Information Security Management System
• ISO 9001 — Quality Management System
• International privacy principles including GDPR and CCPA

If you require additional information, please contact us at: pdp@senmonka.co.id.

1. Consent

By accessing or using our website or services, you acknowledge and agree to this Privacy Policy and consent to the processing of your Personal Data in accordance with applicable regulations.

2. Scope

This Policy applies to Personal Data collected through online activities on www.senmonka.co.id and SMB’s digital services. It does not apply to offline data collection or data processed by third parties outside SMB’s control.

3. Interpretation and Key Definitions

• Personal Data: Any information relating to an identified or identifiable individual.
• Device: Any device used to access the services (computer, smartphone, tablet).
• Service Provider: Third parties that process data on behalf of SMB.
• Usage Data: Automatically collected information such as IP address, browser type, pages visited, and timestamps.

4. Information We Collect

4.1 Data You Provide Directly

We may collect:

• Name
• Email address
• Phone number
• Company name and address
• Message content and file attachments
• Any additional information voluntarily submitted

4.2 Automatically Collected Data (Log & Usage Data)

We collect:

• IP address, browser type, browser version
• Visit date/time, referring pages, exit pages
• Number of clicks, device identifiers
• Diagnostic and analytical data

4.3 Cookies & Tracking Technologies

We use session and persistent cookies, web beacons, scripts, and similar technologies to store preferences, enhance user experience, and analyze usage. You may disable cookies through browser settings; however some features may not function properly.

5. Legal Basis for Processing (PDP Law, GDPR Principles)

We process Personal Data based on:

• Your explicit consent
• Contractual necessity
• Legal obligations
• Legitimate interests of SMB (security, service improvement, fraud prevention)

All processing adheres to transparency, purpose limitation, proportionality, and security principles.

6. How We Use Personal Data

• To operate and maintain SMB services
• To improve performance and personalize user experience
• To analyze usage and develop new products or features
• To communicate with you regarding services, support, or updates
• To send service-related or promotional emails (with consent)
• To detect, prevent, and address fraud or misuse
• To fulfill compliance under ISO 27001 and ISO 9001

7. Disclosure of Personal Data

We may share your Personal Data with:

• Service providers (hosting, analytics, email services)
• Advertising partners (Google, Meta) when applicable
• Affiliated companies within SMB’s corporate structure
• Authorities when required by law
• Other parties with your explicit consent

All third parties must comply with data processing agreements aligned with PDP Law.

8. International Data Transfers

Your data may be stored or processed outside Indonesia. By using SMB services, you consent to cross-border data transfer where appropriate protections are in place.

9. Data Retention

We retain Personal Data as long as necessary for processing purposes or to comply with legal and ISO requirements. After retention periods end, data will be securely deleted or anonymized.

10. Your Rights (PDP Law, GDPR, CCPA)

You have the right to:

• Information regarding processing activities
• Access your Personal Data
• Request correction or updates
• Request deletion (under certain conditions)
• Restrict or object to processing
• Withdraw consent at any time
• Request data portability
• Submit complaints to the relevant authority

CCPA rights (for applicable users): request categories of collected data, request deletion, and request that data is not sold. SMB does not sell Personal Data.

11. Data Deletion & Access

You may request access, correction, or deletion of your data through account settings (if available) or by contacting SMB. Some data may be retained when required by law or legitimate interests.

12. Information Security (ISO 27001) & Quality (ISO 9001)

SMB implements technical and organizational controls aligned with ISO/IEC 27001, such as:

• Role-based access control
• Encryption where applicable
• Security monitoring and incident detection
• Risk assessment and mitigation
• Backup and business continuity procedures

In line with ISO 9001, SMB maintains quality assurance processes to ensure consistent service delivery and continual improvement.

While we apply commercially reasonable protections, no system is 100% secure.

13. Third-Party Cookies & Advertising Partners

SMB uses certain third-party services that may place cookies, pixels, or other tracking technologies on your device to deliver advertising, measure ad performance, and analyze user behavior. These technologies operate independently and are outside of SMB’s direct control.

Google Ads & DoubleClick (DART Cookie)

Google may use the DART cookie to serve ads based on your visits to our website and other sites across the Internet. You may opt out of Google advertising cookies here: https://policies.google.com/technologies/ads

Meta Ads (Facebook & Instagram Ads)

Meta Platforms (Facebook, Instagram) may use tracking technologies such as the Facebook Pixel to:

• deliver personalized ads,
• measure campaign effectiveness,
• track conversions and user interactions,
• improve audience targeting based on aggregated behavior.

These technologies may collect information such as IP address, device identifiers, pages viewed, and actions taken on our website. SMB does not have access to or control over how Meta processes this data.

You may review and manage your Facebook/Instagram ad preferences here:

• Facebook Privacy Policy
• Facebook Ad Preferences
• Instagram Privacy & Security

General Notice

Please note that SMB does not collect or store the data gathered by these third-party advertising tools. All data processing conducted by Google, Meta, or other partners is governed by their respective Privacy Policies.

14. Legal Disclosure & Business Transactions

We may disclose data to:

• Comply with legal obligations
• Respond to government or court requests
• Protect SMB rights and prevent wrongdoing
• Protect user or public safety

If SMB undergoes merger, acquisition, or asset transfer, Personal Data may be transferred with notice where feasible.

15. Children’s Privacy

SMB does not knowingly collect data from children under 13. If you become aware such data was provided without parental consent, contact us for removal.

16. Links to Other Websites

SMB is not responsible for the content or privacy practices of third-party sites. We encourage reviewing their Privacy Policies before providing Personal Data.

17. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Changes will be posted on this page and notified via email or service notice when required.

18. Contact Us

If you have questions or wish to exercise your rights, contact:

PT Senmonka Milenia Bisnis (SMB)
Address: Jl. Raya Legok Parung Panjang – Babakan Barat, Ruko No. 1A dan 1 B RT.003 RW.005, Kel. Babakan, Kec. Legok, Kab. Tangerang, Prov. Banten – Indonesia 15820
Email: pdp@senmonka.co.id
Phone: +6221 5084 7755
Website: www.senmonka.co.id