Privacy Policy

This Privacy Policy constitutes a real commitment from PT. Bos Tobos Indonesia to respect and protect all personal data or information of Bos2bos app Users. We are committed to providing security and comfort for you by using Bos2bos services available through the iOS and Android applications.

This Privacy Policy applies as long as the user accesses our application. If our products or services and affiliated companies use products or services provided by PT Bos Tobos Indonesia but do not have an independent Privacy Policy, this policy also applies to those products or services. Where we and our affiliates have a separate Privacy Policy for the products or services they provide to you, that Privacy Policy will also apply to the related product or service.

By clicking “Register” or any similar statement available on the Site registration page, the User represents that every Personal Data of the User is true and valid data, the User acknowledges that the User has been notified and understands the terms of this Privacy Policy and the User grants consent to Bos2bos to obtain, collect, process, analyze, display, transfer, open, store, modify, remove and/or use the data for the purposes as set out in the Privacy Policy. The Privacy Policy is written in both Bahasa Indonesia, English, and Chinese language. In case of conflict or discrepancies between both languages, the Bahasa Indonesia version will prevail.

1. Obtainment and Collection of Users’ Personal Data
2. Use of Users’ Personal Data
3. Disclosure and Transfer of Users’ Personal Data
4. Cookies
5. User Selection and Transparency
6. Security, Storage and Removal of Users’ Personal Data
7. Access and Correction of Users’ Personal Data or Consent Withdrawal
8. Complaints related to Protection of Users’ Personal Data
9. Contact Us
10. Privacy Policy Update

A. Obtainment and Collection of Users’ Personal Data

Bos2bos collects User's Personal Data for processing User transactions, managing and easing the process of using the App as described in this Privacy Policy, and for other purposes insofar as permissible under the applicable laws and regulations. The collected Users' Data are as follows:

1. Data provided independently by the User, including but not limited to data provided at the time the User:

a. Create or update Bos2bos account, including among others username, email address, telephone number, password, address, photos, and other identifying information of the User;
b. Contacts Bos2bos, Including through customer service;
c. Fills out a survey sent by Bos2bos or other parties officially appointed to represent Bos2bos;
d. Interacts with other Users through messaging feature, product discussion, review, rating, Resolution Center (as defined in the Terms and Conditions), and other interactive features (Whether one or two way) available on the App;
e. Uses services on the App, including detailed transactions data, among others the type, number, and/or description of products or services being purchased, shipping address, payment channel being used, number of transactions, date and time of transaction, as well as other transaction details;
f. Fills in payment data at the time the User conducts a payment transaction activity through the App, including but not limited to bank account data, credit card, electronic money/wallet, virtual account, instant payment, internet banking, retail stores; and/or
g. Uses features on the App which require access permission to the relevant data stored in the User’s device.

2. Data stored at the time the User uses the App, including but not limited to:

a. Real or approximate location data such as IP address, Wi-Fi location, and Geo-location; b. Data in the form of the time of every activity of a User in relation to the use of App, including the time of registration, login, and transaction;
c. User usage or preference data, including User interactions in using the App, saved selection and selected setting. The data is obtained using cookies, pixel tags, and similar technologies that create and maintain a unique identifier;
d. Device data, among others the device type used to access the App, including hardware model, operating system and its version, software, IMEI number, file name, and its version, language selection, unique device identifier, advertising identifier, serial number, device movement information, and/or cellular network information; and/or
e. Log data, including logs on server receiving the data such as device IP address, access date and time, application features or pages viewed, application work process and other system activities, browser type, and/or third-party sites or services used by the User before interacting with the App.

3. Data obtained from other sources, including but not limited to:

a. Data in the form of geo-location (GPS) from Bos2bos business partners that help Bos2bos in developing and offering services on the Site to Users, among others payment service providers, logistics or couriers, site infrastructure partners, and other partners.
b. Data in the form of email, telephone number, name, gender, and/or date of birth of Bos2bos business partners where the User creates or accesses the Bos2bos account, such as social media services, or sites/applications that used by Bos2bos
c. Data from financial service providers, including but not limited to credit rating agencies or bureaus or Credit Information Management Institutions (Lembaga Pengelola Informasi Perkreditan or LPIP).
d. Data in the form of email from marketing service providers.

Bos2bos may combine data obtained from such sources with other data it has.

B. Use of Users’ Personal Data

Bos2bos may use Personal Data obtained and collected from Users as provided in the previous section for the following purposes:

1. Processing of all forms of requests, activities, and transactions made by Users through the App, including for the purpose of delivering products to Users.
2. Provide promotional information if there are new product offers or promotions, special offers, or other information that must be provided to users of the Bos2bos App.
3. In an event/case in an effort to enforce the law or the requirements and obligations of the applicable legislation. Bos2bos will use and disclose users' Personal Data in the event of a dispute or suspected criminal act such as fraud or data theft.
4. Bos2bos is not responsible for all content, whether publicly posted or privately transmitted as it is the sole responsibility of the content creator. This means that Bos2bos is not solely responsible for all content uploaded, posted, emailed, transmitted, or otherwise made available through the Website.
5. Carry out our obligations in order to carry out cooperation with third parties or the like.
6. Help users when communicating with the Bos2bos application, including to:

a. Check, identify, and solve User’s problems;
b. Direct the User's questions to the appropriate customer service officer to solve the problem;
c. Supervise and refine customer service responses;
d. Contacts User via email, mail, telephone, fax, and other communication methods, including but not limited to, to assist and/or complete the transaction process or the process of resolving obstacles, as well as to deliver news or other notifications in connection with the protection of user's personal data, including failure to protect User's personal data;
e. Use information obtained from User for the purpose of research, analyze, product development, and testing in order to improve the security of services on the Site, as well as develop new features and products; and
f. Inform the User regarding products, services, promotions, studies, surveys, news, latest developments, events, and other information, either through the Site or through other media. Bos2bos may also use the information to promote and process contests and ballots, award prizes, and serve relevant advertisements and content about the Bos2Bos app.

7. Monitor and investigate suspicious transactions or transactions indicated to contain elements of fraud or violation of the Terms and Conditions or applicable legal provisions, as well as taking the necessary actions as a follow-up to the results of the monitoring or investigation of such transactions.
8. In certain events, Bos2bos may be required to use or disclose the User's Personal Data for the purpose of law enforcement or to fulfill the requirement and obligation under the applicable laws and regulations, including in the event of a dispute or legal process between a User and Bos2bos, or alleged criminal offense such as fraud or data theft.
9. Facilitating transactions of merger, sales of company’s assets, consolidation or restructuring, financing or acquisition involving Bos2bos.

C. Disclosure and Transfer of Users’ Personal Data

1. Bos2bos is committed to maintain confidentiality of User's personal data which is under Bos2bos controls and warrants that there is no disclosure, sale, transfer, distribution, and/or borrowing of User's Personal Data to other third parties, without the consent of the User, except in the following cases :

a. It is required to disclosure the User's Personal Data to other third parties assisting Bos2bos in providing services that are available or services that will later be available on the site and in processing all forms of the User's activities on the site, including processing transactions, verification of payments, promotions and product delivery.
b. Bos2bos may provide User’s Personal Data to Business partners in accordance with the User's consent to use the business partner's services, including among other applications or sites that have integrated their API or services with each other, or Bos2bos has collaborated to organize promotions, competitions, or special services available on the application.
c. Bos2bos may provide the User's Personal Data to third parties that use and integrate the public API provided by Bos2bos with the applications or site operated by such third parties for the purpose of settling transactions between Buyers and Sellers on the Site or other purposes of using the Personal Data as described in Section B of this Privacy Policy.
d. There is a need for communication between Bos2bos Business Partners such as logistic providers, payment providers, feature providers, or other service facilities and the User in resolving problems or other matters.
e. Bos2bos may provide the User's Personal Data to vendors, consultants, marketing partners, research firms/agencies, or similar service providers for the purpose of marketing activities conducted by third parties, improvement and maintenance of the quality of Bos2bos services, as well as other publication activities.
f. When the User contacts Bos2bos through public media such as blog, social media, and certain features on the site, where the communication between the User and Bos2bos can be viewed and known by the public.
g. Bos2bos may share the User's Personal Data to its subsidiary and affiliate to assist the provision of service or conduct data processing for and on behalf of Bos2bos.
h. Bos2bos may disclose and/or provide the User's Personal Data to interested parties for the purpose of conducting creditworthiness analysis.
i. Bos2bos shall disclose the User's Personal Data in an effort to comply with legal obligations and/or official requests from law enforcement or authorized state agencies.

2. In relation to the disclosure of Users Personal Data as described above, Bos2bos will/may be required to disclose Users Personal Data to third-party services providers, agents and/or affiliates or relevant companies of Bos2bos, and/or other third parties located outside the territory of Indonesia. However, such third-party service providers, agents and/or affiliates or relevant companies and/or other third parties shall only manage and/or utilize Users Personal Data in connection with one or more purposes as set out in this privacy policy and in accordance with the provisions of the applicable laws and regulations.

D. Cookies

1. Cookies mean small files that will automatically take place on the User's device which stores User preferences and configurations while visiting a site.
2. Cookies are not intended to be used when accessing other data that the User has on the User's computer device, other than what the User has agreed to submit.
3. Although the User's computer device will automatically accept cookies, the User may choose to make modifications through the User's browser setting, namely by choosing to reject cookies (this option may hinder the optimal availability of Bos2bos services when the User accesses the site).
4. Bos2bos is using Google Analytics Demographics and interesting features. Data obtained by Bos2bos from such features, such as age, gender, User's interest, and other identifiable information of the User, will be used by Bos2bos for the development of features, facilities, and/or contents available on Bos2bos site. If the User does not wish for Google Analytics to track the User's data, the User may use Add-On Google Analytics Opt-Out Browser.
5. Bos2bos may use the features provided by third parties for the purpose of improving Bos2bos services and contents, including the assessment, adjustment, and serving of advertisements to every User based on their interest or visit history. If the User does not wish for any advertisement to be displayed based on such adjustment, the User may set it via browser.

E. User Selection and Transparency

1. Mobile devices in general (iOS and Android) have settings so that the Bos2bos application cannot access certain data without the consent of the User. The iOS device will notify the User when the Bos2bos application first requests access to the data, while the Android device will notify the User when the Bos2bos application is first installed. By using the application and providing access to the application, the User is deemed to have given his/her consent to the collection and use of the User’s Personal Data on his/her device.
2. After a successful sale and purchase transaction on the Site, the Seller and the Buyer (as defined in the Terms and Conditions) have the opportunity to rate and review one another. This information may be publicly viewable with the User's consent.
3. Users may access and modify information in the form of email address, telephone number, date of birth, gender, address list, payment method, and bank account through settings feature on the site.
4. Users may opt out from information or notifications in the form of newsletters, reviews, product discussions, private messages, or private messages from the Admin sent by Bos2bos through the settings feature on the Site. Bos2bos may still send messages or emails in the form of transaction information or information related to the User's account.
5. Insofar as not in contradiction with the provisions of the applicable laws and regulations, the User may contact Bos2bos to withdraw the consent for the obtainment, collection, storage, management, and use of the User's data. In such an event, the User understands the consequence that the User may no longer use the services of the Site and other Bos2bos services.

F. Security, Storage and Removal of Users’ Personal Data

1. Bos2bos protects every User’s Personal Data stored in its system, and protects such data from any unauthorized access, use, modification, collection, and/or disclosure by using a number of security measures and procedures, including password and OTP (One Time Password) code that will be sent to User’s phone number.
2. User's Personal Data may also be stored or processed abroad by parties working with Bos2bos in other countries, or by third-party service providers, vendors, suppliers, partners, contractors, or affiliates of Bos2bos. In such event, Bos2bos shall ensure that the Personal Data remains protected pursuant to Bos2bos commitment in this Privacy Policy.
3. Even though Bos2bos has used its best effort to secure and protect the User's Personal Data, it should be noted that data transmission over the Internet is never fully secured. Therefore, Bos2bos is unable to guarantee 100% the security of the data provided or transmitted to Bos2bos by the User, and the provision of information by the User shall be at the User's own risk.
4. Bos2bos shall delete and/or anonymize the User's Personal Data that is under Bos2bos control in the event (i) the User's Personal Data is no longer required to fulfill the purpose of its collection; and (ii) retention is no longer required for the purpose of compliance with the applicable laws and regulations.
5. Please note that there remains a possibility that some of User’s Personal Data is stored by other parties, including the authorized state agencies. In the event that we share the User's Personal Data with the authorized state agencies and/or other agencies that may be appointed by the authorized government or cooperation with Bos2bos, the User agrees and acknowledges that the retention of the User's Personal Data by a such agency will follow the data retention policy of each agency.

G. Access and Correction of Users’ Personal Data or Consent Withdrawal

1. Bos2bos shall take reasonable measures to ensure that the User's Personal Data is processed accurately and completely. However, it is important for the User to promptly notify Bos2bos of any change in the User's Personal Data or in the event of any inaccuracy of the User's Personal Data that is under Bos2bos control.
2. The User’s shall be entitled to access or modify their own Personal Data that is under Bos2bos control via Bos2bos customer service available in this Privacy Policy. However, such requests shall only be processed by Bos2bos if the User has submitted sufficient proof of identity to access or modify the data. Bos2bos reserves the right to reject the request to access, or to modify, part or all of the User's Personal Data owned or controlled by Bos2bos insofar permitted or required under the applicable laws and regulations. This includes circumstances where the Personal Data may contain references to other people or where the access request or modification request is for reasons that is deemed irrelevant, inconsequential, or difficult by Bos2bos.
3. Bos2bos may charge administration fees to the User to handle the User's request for access or correction of the User's Personal Data.
4. The User may withdraw the consent granted by the User in relation to the processing of the User's Personal Data that is under Bos2bos control by submitting such request through Bos2bos customer service provided in this Privacy Policy. Bos2bos shall process the User's request within a reasonable period of time as of the submission of the consent withdrawal request, and shall not further process the User's Personal Data pursuant to the User's initial request unless required by the applicable laws and regulations. In the event of a consent withdrawal, Bos2bos may no longer be able to perform its obligations based on any agreement between the User and Bos2bos. In this regard, there is also a possibility that since Bos2bos is no longer able to perform its obligations due to the withdrawal of consent by the User, any legal relationship between the User and Bos2bos would terminate and cannot be continued.

H. Complaints related to Protection of Users’ Personal Data

1. If the User has any concern with regard to the handling or treatment of Bos2bos to the User’s Personal Data or if the User believes that the User’s privacy has been breached, User may contact Bos2bos through Bos2bos customer service or to the Bos2bos contact provided in this Privacy Policy by describing the identity and nature of complaint of the User.
2. Bos2bos shall investigate all User’s complaints and attempt to provide a response to such complaints within a reasonable period of time after receiving the complaint submitted by User.

I. Contact Us

To Bos2bos users who have questions, comments, complaints, or other things about this Privacy Policy or users wishing to correct their Personal Data can contact Bos2bos customer service via email at cs.bos2bos@gmail.com or via WhatsApp +62 895- 3351-63574.

J. Privacy Policy Update

Bos2bos may make changes or updates to this Privacy Policy at any time. Bos2bos recommends that Users carefully read and check this Privacy Policy page from time to time for any changes. By continuing to access and use the Site services and other Bos2bos services, the User is deemed to agree to the changes in the Privacy Policy.