1.About us
Makasee (collectively Makasee, we or us) understands the importance of protecting the privacy of an individual’s personal information. This Privacy Policy (Policy) outlines how we will comply with our obligations under Indonesian privacy laws.
To the extent that the handling of your personal information is governed by the General Data Protection Regulation 2016/679 (GDPR) i.e. Makasee holds, controls or processes personal data of residents of the European Economic Area, then additional obligations will apply to us. In most cases, Makasee is primarily the “controller” of your personal information and we will provide our services in a way such that personal information will be processed fairly, lawfully and in a transparent manner, and collected and processed only for a specified and lawful purpose.
This Policy sets out how we collect, hold, use and disclose your personal information, and how we maintain the quality and security of that personal information. It also sets out your rights in relation to your personal information managed by Makasee and what you can do if you are concerned with how we handle your personal information.
2. What kind of information do we collect?
2.1 What is “personal information”?
“Personal information” means any information or opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. In general terms, this includes information or an opinion that personally identifies you either directly (e.g. your name) or indirectly.
Where the GDPR applies, “personal information” will also include “personal data” as defined in GDPR.
2.2 What types of personal information do we collect?
Given the nature of services we provide, we collect different types of information about you depending on the nature of our relationship with you, and what you choose to share with us. We try to minimise the collection of information to only what is reasonably necessary for us to perform one or more of our functions or activities.
We may collect the following personal information from you:
We may also collect, monitor and use certain information about your usage of our website https://www.makasee.io/ and the Makasee platform (Website), including:
For completeness, we note that we do not collect any sensitive information (e.g. health-related or biometric information) or credit-related information. All credit-related information is collected and stored directly by the relevant third party payment providers e.g. PayPal.
3. How does Makasee collect personal information?
3.1 Direct collection
We may collect personal information directly from you:
3.2 Indirect collection
We may also collect personal information indirectly through third parties where you would reasonably expect us to do so. For example, we may collect personal information:
If you wish to understand what personal information we have collected about you from other sources, please contact our Privacy / Data Protection Officer (see section 13 of this Policy).
3.3 Unsolicited information
From time to time, we may receive personal information that is additional to information that we have solicited or information that we have not taken active steps to collect. This is known as ‘unsolicited personal information’ and can include:
If we receive unsolicited personal information and we decide that we are not permitted to collect it in accordance with the APPs, we will take reasonable steps to destroy or de-identify the information as soon as practicable, unless it is unlawful or unreasonable to do so.
4. Consent
By creating an account on our Website, submitting forms on our Website or the merchant’s website or continuing to use Makasee’s services, you consent for us to obtain, store, process and handle your information (including personal information), in accordance with this Policy and all applicable privacy laws.
5. Why does Makasee need your personal information?
We collect, use, hold and disclose your personal information for a purpose related to the provision of conducting delivery, logistics and transportation services and/or where we have obtained your consent. In particular, we may use your personal information to:
We may collect certain information from you in relation to your website visits and online activity. This may in some circumstances constitute ‘profiling’ under the GDPR. Furthermore, Makasee may undertake ‘profiling’ to personalise your website experience, our communications with you and improve our service offerings to you. For further information, please refer to Sections 9 and 11 of this Policy.
We will only use personal information for a purpose other than for which it was collected or a related purpose if you have consented to such different use or where we may otherwise be reasonably expected to do so. To the extent we will use your personal information for a purpose other than for which it was collected, we will contact you to provide further information.
5.1 Direct marketing
From time to time, we may send you direct marketing communications, opportunities, or new product offerings that we consider may be of interest to you if:
We may send you messages or advertisements about these communications via your email, our Website, SMS, phone or mail, in compliance with applicable marketing laws (including the Spam Act 2003 (Cth)).
You can choose to not receive these communications from us at any time and you may opt out by following the opt-out instructions that can be found in any of these communications.
If you choose to opt out, please note that you will still receive communications from us which are necessary for facilitating your use of Makasee’s services or Website.
6. What do we do with your personal information?
6.1 Who do we disclose your personal information to?
We disclose your personal information for the purpose that we collect it for. That is, generally, we will only disclose your personal information for a purpose related to the provision of conducting delivery, logistics and transportation services. Accordingly, we may disclose your personal information to:
We will not sell your personal information to other people, and always aim to use your information to provide you with a suitable service. We have strict access management processes in place to ensure information is only shared on a ‘need-to-know’ basis.
To the extent we disclose your personal information to third parties, we will use reasonable commercial efforts to ensure that these third parties only use your personal data as reasonably required, and to protect your personal information in a manner that is consistent with applicable privacy laws.
We generally do not disclose personal information in circumstances other than as outlined above. However, we may disclose personal information with your consent, or if it is required or authorised by law (including in emergency situations relating to the life, health, or safety of any individual or to assist law enforcement), or if we have reason to believe that unlawful activity or misconduct of a serious nature is being engaged in and we should disclose your information in relation to the matter.
6.2 Transfer of personal information outside the country in which it was collected
We endeavour to retain your information and personal information on servers located in your country. However, there may be certain circumstances where we need to disclose or transfer your personal information to third parties and service providers that are located outside the country in which you live. This includes our service providers that are located overseas (including the Philippines).
To the extent that your personal information is disclosed to third parties that are located overseas, we will take reasonable steps to ensure that the third party does not breach the privacy obligations relating to your personal information (e.g. by entering into an enforceable contractual arrangement with the overseas recipient that requires the recipient to handle the personal information in accordance with those privacy laws).
For further information on international transfers and how we safeguard your personal information, please contact our Privacy / Data Protection Officer.
6.3 How do we hold your personal information
We may hold your personal information in either electronic or hard copy form. If you provide your personal information to us electronically via our Website, we retain this personal information in our computer systems and databases. This includes computer software programs, internet servers and hosted internet solutions provided by third parties.
7. Security of your personal information
We take the security of personal information seriously and all reasonable steps are taken to ensure the security of personal information to protect it against loss, unauthorised access, use, modification or disclosure, and against other misuse. Our technical and organisational security measures include:
We also take measures in respect of destroying or de-identifying personal information that is no longer needed for any lawful purpose. We reserve the right to transfer or sell de-identified personal information and data to third parties.
We cannot guarantee the security of any personal information that is transmitted to or by us over the internet, and we note that the transmission and exchange of personal information is carried out at your own risk. But we do take measures to safeguard against unauthorised disclosures of personal information that is within our control.
8. Accessing, correcting, updating or deleting your personal information
You have legal rights in relation to your personal information, including the right to withdraw your consent for us to hold, use or disclose your personal information at any time. Please be aware that some of your rights are subject to exemptions and may not always apply.
8.1 Accessing your personal information
If at any time you would like to access the personal information that we hold about you, please contact our Privacy / Data Protection Officer (see section 13 of this Policy). We will provide this access to you once we have verified your identity. We will also take steps reasonable in the circumstance to provide you with access in a manner that meets your needs as well as ours. Please allow at least 30 days for processing of a request. For the provision of access, we may charge you a reasonable administration fee, which reflects and will not exceed the cost to us for providing access in accordance with your request. If we refuse your request, we will provide you with written reasons for the refusal and details of complaint mechanisms.
8.2 Correcting and updating your personal information
To the extent you believe the personal information we hold about you is incorrect, incomplete or inaccurate, then you can ask us to amend it by contacting our Privacy / Data Protection Officer (see section 13 of this Policy). Requests will be responded to within a reasonable period of time after verifying your identity unless it is unreasonable or impracticable to do so. Please allow at least [30] days for processing of a request. Where an update to your personal information is made, you may also request us to take reasonable steps to distribute the corrected information to other recipients who had access to the initial data.
All reasonable steps to comply with a correction request will be made, unless it is inappropriate to make the changes you request or there is a need to keep information for legal, auditing or internal risk management reasons. In that case, we will contact you to explain why.
8.3 Additional GDPR rights
To the extent that the GDPR applies to the collection of your personal information, you have (in some circumstances) the right to request:
If we refuse any of these requests, we will provide you with written reasons for the refusal and details of complaint mechanisms.
9. Cookies
Our Website uses “cookies”. A cookie is a small file of letters and numbers a website puts on your device if you allow it. These cookies recognise when your device has visited our website before, so we can distinguish you from other users of our Website. This improves your experience and our Website.
If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, please be aware that your browsing experience and our Website’s functionality may be affected.
10. Social networking services
We use social networking services such as Facebook, Twitter and LinkedIn to communicate with the public about our services. When you communicate with us using these social networking services, we may collect your personal information, but we only use it to help us to communicate with you.
The social networking service will also handle your personal information for its own purposes. These services have their own privacy policies – you can access the privacy policies for these companies on their websites.
11. Website Analytics
Our website uses analytics platforms and tools, such as ZoomInfo, and first-party tracking, to help us better understand visitor traffic so we can improve our services. Although this data is mostly anonymous and will not identify an individual, it is possible that we may connect it to you in some circumstances.
12. Links to third party sites
Our Website may contain links and banners to websites operated by third parties. If you access a third-party website through our Website, personal information may be collected by that third party website. We make no representations or warranties in relation to the privacy practices of any third party provider or website and we are not responsible for the privacy policies or the content of any third party provider or website. Third party providers / websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies.
13. How to make a complaint or contact us
If you have any questions, comments, or complaints about our collecting, storing, or handling of personal information, or if you believe that we have not complied with this Policy, please contact our Privacy / Data Protection Officer.
In the case of lodging a complaint, you will be asked to provide proof of your identity and full details of your request in writing before we can process your complaint. Please allow up to 30 days for us to respond to your complaint.
At all times, privacy complaints:
To the extent we are unable to satisfactorily resolve your complaint, you have the right to contact the relevant local data protection authority to lodge a complaint.
14. Updates to the Privacy Policy
We regularly review our practices and procedures in relation to the handling of personal information. As a result, we reserve the right to periodically change or update this Policy from time to time. Updated versions of this Policy will be posted on our Website. Please ensure that you review our Website regularly to be advised of updates.
If at any point we decide to use personal information in a manner materially different from that stated at the time it was collected, we will notify individuals by email or via a prominent notice on our website, and where necessary we will seek the prior consent of individuals.
This statement was last reviewed and updated on 1 September 2023.