PRIVACY POLICY

General Privacy Policy

Last Update: 30 September 2024

This privacy policy (the "Privacy Policy") discloses the privacy practices for PT Higo Fitur Indonesia on its website higo.id (the "Website") and through the services it offers elsewhere and otherwise (including its on-site free WiFi service) (together with the Website, the "Services"). PT Higo Fitur Indonesia. ("HIGOspot Social and Free WiFi"), the provider of the Services (referred to as "us" or "we"), is committed to protecting your privacy. Please read the following to learn what information we collect from you (the "User" or the "End User") and how we use that information. If you have any questions about our privacy policy, please email us at info@higo.id atau legal@higo.id

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING OUR WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND TO ALL THE TERMS OF THIS PRIVACY POLICY, OUR WEBSITE TERMS OF SERVICE AND/OR OUR ON-SITE WIFI TERMS OF SERVICE. IF YOU DO NOT AGREE TO THESE TERMS, EXIT THIS PAGE AND DO NOT ACCESS OR USE THE WEBSITE OR OUR SERVICES. YOU CAN OPT-OUT HERE TO DELETE ANY EXISTING LOCATION DATA, AND STOP ANY FURTHER DATA FROM BEING COLLECTED FOR YOUR DEVICE.

1. Changes to Privacy Policy

If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy in places within the Services and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, or by email, or by means of notice on the Services.

2. Types of Information Collected & Uses of Collected Information

We collect two types of information about Users of our Services: Personally Identifiable Information and Non-Personally Identifiable Information. Personally Identifiable Information. Personally Identifiable Information is information that identifies a specific End User. When you engage in certain activities on the Services, such as creating an account, ordering a product or service from us, submitting content, filling out a survey, sending us or our partners feedback, requesting information about our services, submitting an agreement, applying for a job or authorizing HIGOspot Social WiFi and HIGOspot Free WiFi to access your Facebook account so you can access WiFi at one of our affiliate locations (collectively, "Identification Activities"), we may ask you to provide certain information about yourself. It is optional for you to engage in an Identification Activity. If you elect to engage in an Identification Activity, however, we may ask you to provide us with certain personal information about yourself, such as your first and last name, user name, gender, mailing address (including postal code/zip code), email address, telephone number, and date of birth. When you order products or services, we may also ask you to provide us with your credit card number, expiration date and authentication codes or related information. Depending on the activity, some of the information we ask you to provide is identified as mandatory and some is identified as voluntary. If you do not provide the mandatory information for a particular activity that requires it, you will not be permitted to engage in that activity. We use Personally Identifiable Information to enhance the operation of the Services, improve our marketing and promotional efforts, analyze Services use, improve our product and service offerings, and to tailor your experience with third parties as provided in Item 3 of this Privacy Policy. For example, if you send our customer service an email we may use your comments and feedback to tell others about our services, and may post your comment in our marketing materials or on our Services. Your comments may contain personal information such as your name and we will obtain consent from you to post your name along with your comment prior to posting your comment for public view. In addition, if you use our Services to send information or a contest, product or service to another person, we may store your personal information. We may also use Personally Identifiable Information to troubleshoot, resolve disputes, accomplish administrative tasks, contact you, enforce our agreements with you, including our Website Terms of Service, our On-Site WiFi Terms of Service and this Privacy Policy, comply with applicable law, and cooperate with law enforcement activities. Furthermore, in order to access certain aspects of the Services, you must allow HIGOspot Social WiFi and HIGOspot Free WiFi to access your Facebook account using Facebook’s "OAuth" authorization procedure. By authorizing HIGOspot Social WiFi and HIGOspot Free WiFi to access your Facebook account, you hereby grant HIGOspot Social WiFi and HIGOspot Free WiFi access to certain information in your Facebook profile, including but not necessarily limited to: basic information including (but not limited to) age, birthdate, name, gender, location, email address; extended profile information including (but not limited to) events, check-ins, "likes", interests, friends, friends of friends, groups, etc.; and, other information which the OAuth procedure allows HIGOspot Social WiFi and HIGOspot Free WiFi to access. If at any point the information HIGOspot Social WiFi and HIGOspot Free WiFi requires by your access necessitates a higher level of Facebook profile access through OAuth authorization, these Terms and Conditions shall be amended accordingly and HIGOspot Social WiFi and HIGOspot Free WiFi will notify you of said changes in the manner set forth above. By allowing HIGOspot Social WiFi and HIGOspot Free WiFi to access your Facebook profile through the OAuth procedure, you hereby agree to any and all terms and conditions imposed on you by Facebook, Inc. in connection with the OAuth procedure, your use of the Facebook website and any and all sites and/or applications and/or other data or content in connection therewith. Non-Personally Identifiable Information. Non-Personally Identifiable Information is information that does not identify a specific End User. This type of information may include (but is not necessarily limited to) things like the Uniform Resource Locator ("URL") of the website you visited before coming to our Website, the URL of the website you visit after leaving our Website, the type of browser you are using, the MAC address of your mobile device, the type of mobile device you may be using to access the Services, and your Internet Protocol ("IP") address. We may automatically collect this information when you use our Services through the use of electronic tools like Cookies and Web beacons or Pixel tags. We use Non-Personally Identifiable Information to troubleshoot, administer the Services, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized Third Party Service Providers, Third Party Advertisers and Affiliates to measure the overall effectiveness of our online advertising, content, and programming. Linking of MAC Address to Personally Identifiable Information. You understand and agree that by engaging in certain Identification Activities, you are permitting us to: a) store and access your Personally Identifiable Information; b) link your Personally Identifiable Information to the MAC address and your location, as offered by the device with which you access the Internet and/or our WiFi service; and, c) use your Personally Identifiable Information in such other ways which accord with the terms and conditions herein set forth.

The data you provide to us will only be stored as long as necessary to fulfill the purpose of collecting and storing the data as long as you are a user of the service or until you request deletion of your data to us. We comply with legal and reporting requirements based on existing regulations. We also determine the retention period by considering the amount, nature, and type of data that has the potential or danger of unauthorized disclosure of your data.

3. Release of Personally Identifiable Information

We will not share, sell, rent, or trade your Personally Identifiable Information with other parties except as provided for within this Privacy Policy. "Third Party Service Providers" perform functions on our behalf, like sending out and distributing our administrative and promotional emails. We may share your Personally Identifiable Information with such Third Party Service Providers to fulfill orders, deliver packages, send postal or email, remove repetitive information on customer lists, analyze data, provide marketing assistance, provide search results and links, process credit card payments, operate the Services, troubleshoot, and provide customer service. We may also share your information with individuals or companies with whom we have a contractual relationship to provide certain aspects of the Services, and in particular those entities who a) are registered clients of HIGOspot Social WiFi and HIGOspot Free WiFi; b) with whom HIGOspot Social WiFi and HIGOspot Free WiFi has a contractual relationship to share Personally Identifiable Information; and/or c) at whose location or facility there is a HIGOspot Social WiFi and HIGOspot Free WiFi "hotspot" by which you can access free WiFi (each an "Affiliate" and collectively, "Affiliates"). Sharing this Personally Identifiable Information may allow an Affiliate (as defined below) and/or HIGOspot Social WiFi and HIGOspot Free WiFi to market directly to you should they choose to do so. However, we will only share Personally Identifiable Information with Affiliates if you engage in an Identification Activity, and then only to the Affiliate involved in that Identification Activity. We specifically disclaim any responsibility or liability for the actions of such Affiliate. While we inform them that they are only permitted to communicate with you for the purposes of the specific promotion with HIGOspot Social WiFi and HIGOspot Free WiFi, we do not have any responsibility for the actions of the Affiliate, and the actions of the Affiliate are not in our control. We may share your information with such Affiliates to accomplish our administrative tasks and/or to fulfill our obligations to said Affiliates, including, but not limited to, the obligation to provide said Affiliates with analytics data regarding your use of their services, your use of our Services at their location, your presence on-site, and other Personally Identifiable Information which is valuable to our Affiliates. We encourage our Affiliates and Third Party Service Providers to adopt and post privacy policies. However, the use of your Personally Identifiable Information by such parties is governed by the privacy policies of such parties and is not subject to our control and you hereby agree in no way is HIGOspot Social WiFi and HIGOspot Free WiFi liable to you for such Affiliates’ or Third Party Service Providers’ use of your information as collected through the Services. We may also remarket your information. Remarketing is a way for us to connect with users, based upon your past interactions with our Services. Third-party marketing vendors may be hired by HIGOspot Social WiFi and HIGOspot Free WiFi to perform remarketing services. This information is used only for remarketing purposes and will not be used by them for any other purpose. We may also share your information in a business transfer. As with any other business, we could merge with, or be acquired by another company. If this occurs, the successor company would acquire the information we maintain, including Personally Identifiable Information. However, Personally Identifiable Information would remain subject to this Privacy Policy. We may share your information for our protection and the protection of others. We reserve the right to disclose your Personally Identifiable Information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Services; enforce or apply this Privacy Policy, our On-Site WiFi Terms of Service, our Website Terms of Use or other agreements; or protect the rights, property or safety of the Services, its Users or others.

4. Release of Non-Personally Identifiable Information

We may disclose or share Non-Personally Identifiable Information with Third Party Service Providers, Affiliates and Third Party Advertising Advertisers. For example, we may share aggregated demographic information (which does not include any Personally Identifiable Information) with "Third Party Advertisers" or "Third Party Affiliates Companies" and other parties as provided below: in the future, we may use Third Party Affiliates Companies to serve ads when you visit our Website or use our Services otherwise. These companies may use Non-Personally Identifiable Information about your visits to this and other websites in order to provide, through the use of network tags, advertisements about goods and services that may be of interest to you. We also use Third Party Service Providers to track and analyze Non-Personally Identifiable usage and volume statistical information from our Users to administer our Services and constantly improve its quality. We may also publish this information for promotional purposes or as a representative audience for Advertisers. Please note that this is not Personally Identifiable Information, only general summaries of the activities of our Users. Such data is collected on our behalf, and is owned and used by us.

5. Updating & Correcting Information

We believe that you should have the ability to access and edit the Personally Identifiable Information you provide us. You may change any of your Personally Identifiable Information by logging into your account and accessing your account information. We encourage you to promptly update your Personally Identifiable Information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on the Services. In addition, it may be impossible for us to completely delete all of your information because we periodically backup information. If you choose to store credit card information on the site, this is stored on a secure page and you may delete your credit card information at any time by logging in and accessing your account information.

6. User Right & Choices On Collection & Use of Information

As discussed above, you can always choose not to provide information, although it may be required to engage in a certain activity on the Services. As a condition of access to on-site Wifi, we will send you Administrative and Promotional emails. You cannot opt-out of Administrative Emails. "Administrative Emails" relate to a User’s activity on the Website, and include emails regarding a particular User’s account, requests or inquiries, and the purchasing of products and services. In contrast to Administrative Emails, however, you do have a choice with respect to Promotional Emails. "Promotional Emails" advertise our products and services, including sales and other offers, and/or the products and services of our Advertisers and Affiliates. If you do not want to receive Promotional Emails from us, you may elect to opt-out of receiving Promotional Emails at any time after registering, which you may do at any time at privacy.higo.id by following the respected instructions. You understand that you may enter Promotional Emails again after we deem it necessary to do so.

You have rights based on regulation provisions regarding the protection of personal data. The right to obtain access to your data which allows you to request a copy of your data that you provide to us and that we keep. The right to delete data allows you to delete data that you provide to us regarding the use of services or you can request to move data or delete data because you refuse to process data processing. The right to request restrictions on data processing which allows you to ask us that you want to ensure that your data is accurate data and you can set the data according to what you want and you can also ask us to withdraw your data according to what you feel It is necessary that with this right you also fulfill your right to submit an objection to the data you provide to us. The right to correct data that has been provided allows you to ask us for data that you feel is inaccurate and that we may need to verify the accuracy of the data. The right to request use and data transfer which allows you to ask us to send your data to a third party you choose in a clear format and also you will still be able to use your data in places other than our services. If you want to exercise one of your rights above, you need to contact us via our admin or email at info@higo.id.

7. Security of Information

We take security seriously and take numerous precautions to protect the security of Personally Identifiable Information. You can access your Personally Identifiable Information on our Services through a password and your email address. This password is encrypted. We recommend that you do not share your password with anyone. In addition, your Personally Identifiable Information resides on a secure server that only selected personnel and contractors have access to. We encrypt certain sensitive information (such as credit card information) using Secure Socket Layer (SSL) technology to ensure that your Personally Identifiable Information is safe as it is transmitted to us. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with companies which do the same, we cannot guarantee the security of any information transmitted through the Services, and are not responsible for the actions of any third parties that may receive any such information.

8. Data Tracking

Cookies. To facilitate and customize your experience with the Website, we store cookies on your computer. A cookie is a small text file that is stored on a User’s computer for record-keeping purposes which contains information about that User. We use cookies to save you time while using the Website, remind us who you are, and track and target User interests in order to provide a customized experience. Cookies also allow us to collect Non-Personally Identifiable Information from you, like which pages you visited and what links you clicked on. Use of this information helps us to create a more user-friendly experience for all visitors. In addition, we may use Third Party Advertising Companies to display advertisements on our Website. As part of their service, they may place separate cookies on your computer. We have no access to or control over these cookies. This Privacy Policy covers the use of cookies by our Website only and does not cover the use of cookies by any Advertiser. Most browsers automatically accept cookies, but you may be able to modify your browser settings to decline cookies. Please note that if you decline or delete these cookies, some parts of the Website may not work properly. Other Tracking Devices. We may use other industry standard technologies including (but not limited to) pixel tags and web beacons to track your use of our Services, or we may allow our Third Party Service Providers to use these devices on our behalf. Pixel tags and web beacons are tiny graphic images placed on certain pages on our Website, or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, pixel tags and web beacons generate a Non-Personally Identifiable notice of that action. Pixel tags allow us to measure and improve our understanding of visitor traffic and behavior on our Website, as well as give us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our Affiliates and/or Marketing Partners for the same purposes. We may also use your MAC address and certain geolocational technologies to track where you are when you are on one of our wireless networks by use of the Services.

9. Privacy Policies of Third Party Websites

This Privacy Policy only addresses the use and disclosure of information we collect from you through our Services. Other websites (including other websites which host their own or others’ contests) that may be accessible through the Services have their own privacy policies and data collection, use and disclosure practices. If you link to any such website, we urge you review the website’s privacy policy. We are not responsible for the policies or practices of third parties.

10. Children

The service can be used by children starting from 5 (five) years old, and we really respect the provisions regarding child protection (who can access services from 5 (five) years to 17 (seventeen) years old) so that someone who is not yet 18 (eighteen) years old years old can only access parts of the service designed or intended for children under 18 (eighteen) years old by using verification methods when using the service including the reporting mechanism provided for children, parents and/or guardians of children. Our service strongly encourages parents/guardians and adults to monitor and filter the Internet for children under their supervision.

11. Contacting Us

If you have any needs related to claims, complaints, comments, and protection of your data that regulates the provisions of your laws and regulations, you can contact our admin or via email info@higo.id atau legal@higo.id. and if you need further information, you can contact the Ministry of Communication and Informatics.