This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of Personal Information we receive from users of our mobile attendance application (“App”). By using the App, you agree to the collection and use of information in accordance with this policy. This App is intended for use by authorized employees within organizations that have subscribed to our services (“Corporate Users”). Access is granted by your employer or organization administrator.
1. Information Collection And Use
While using our App, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your name, email address, employee ID, and workplace location (“Personal Information”). We use your Personal Information only for providing and improving the App, including processing attendance records and verifying identity.
2. Biometric Data (Face Recognition)
Our App collects and processes biometric data in the form of facial recognition data (face embeddings) for identity verification purposes.
Purpose of Collection:
This data is used solely to:
– Verify user identity during attendance check-in/check-out
– Ensure the registered user is physically present at a designated location
Limitations of Use:
We do NOT use facial data for:
– Tracking users beyond attendance verification
– Marketing or advertising purposes
– Analytics or profiling
User Consent:
Before any facial data is collected, users will be presented with a clear and explicit consent request. You may withdraw your consent at any time by contacting your organization administrator or our support team. Withdrawal of consent may affect your ability to use biometric-based features of the App.
Data Storage:
Facial data is securely stored on our servers using industry-standard encryption and strict access control mechanisms. Only authorized personnel are permitted to access biometric data, and only when necessary for operational purposes.
Data Sharing:
We do not share biometric data with any third parties, including your employer’s other systems, unless explicitly required by applicable Indonesian law or a valid legal order.
Data Retention:
Facial data is retained only for as long as your user account remains active. Upon account deletion, termination of employment, or upon your written request, facial data will be permanently and irreversibly deleted from our servers within 30 days.
Compliance:
The collection and processing of biometric data in this App is conducted in accordance with applicable Indonesian data protection regulations, including Law No. 27 of 2022 on Personal Data Protection (UU PDP).
3. Location Data
The App may request access to your device’s location to verify that attendance is recorded at an authorized workplace location. Location data is used solely for attendance verification and is not stored beyond what is necessary to process each attendance event.
4. Log Data
Like many application operators, we collect information that your device sends whenever you use our App (“Log Data”). This Log Data may include information such as your device’s Internet Protocol (“IP”) address, device type, operating system version, the features of our App that you use, the time and date of your activity, and other diagnostic statistics. We may use third-party services such as analytics tools that collect, monitor, and analyze this data for the purpose of improving App performance and reliability.
5. Communications
We may use your Personal Information to send you important notices related to your account, attendance records, or App updates. Marketing or promotional communications are not applicable to this B2B service. All system communications are managed through your organization’s administrator.
6. Cookies and Local Storage
The App may store small amounts of data locally on your device (such as session tokens) to maintain your login session and improve performance. This data does not include biometric information and is removed upon logout or account termination.
7. Security
The security of your Personal Information, including biometric data, is of utmost importance to us. We implement commercially reasonable and industry-standard security measures, including encryption in transit (TLS) and at rest, to protect your data. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee its absolute security. In the event of a data breach that affects your Personal Information, we will notify the relevant parties in accordance with applicable Indonesian law.
8. Third-Party Services
The App may integrate with third-party services (such as HR systems or payroll software) as directed by your organization. These integrations are governed by separate agreements between us and your employer. We do not share biometric data through any such integrations. We have no control over, and assume no responsibility for, the privacy policies or practices of any third-party sites or services.
9. Children’s Privacy
Our App is designed exclusively for use by employed adults within corporate organizations. We do not knowingly collect Personal Information from individuals under the age of 18. If we become aware that such information has been collected, we will take immediate steps to delete it from our servers.
10. Your Rights
As a user covered under Indonesian data protection law (UU PDP), you have the right to:
– Access the Personal Information we hold about you
– Request correction of inaccurate data
– Request deletion of your data, including biometric data
– Withdraw consent for biometric data processing at any time
– Lodge a complaint with the relevant Indonesian data protection authority
To exercise any of these rights, please contact us or your organization’s administrator.
11. Consent
By using the App, you consent to this Privacy Policy and agree to its terms. For biometric features, a separate and explicit consent will be obtained before collection begins.
12. Updates to Our Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable regulations. We will notify you of any significant changes through the App or via email. You are advised to review this Privacy Policy periodically. Changes are effective when they are posted.
13. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at:
PT MITRA TELEMEDIA MANUNGGAL
Seberang Bale Udang Mang Engking, Jl. Nakula No.11, Pemecutan Klod, Denpasar Barat, Denpasar City, Bali 80361
sysdev@mtmbali.com
(0361) 3352160
