PRIVACY POLICY

PRIVACY POLICY

Effective Date: May 6, 2025

Introduction

Welcome to www.protoflexsuspension.com (the “Website”). This Privacy Policy explains how PT PROTOFLEX RETAIL INTERNASIONAL (“We”, “Us”, “Our”), as the data controller, collects, uses, discloses, stores, and protects your Personal Data in compliance with the EU General Data Protection Regulation (GDPR) where applicable to our interactions with individuals in the European Economic Area (EEA), and Indonesia’s Law No. 27 of 2022 concerning Personal Data Protection (“PDP Law”). This policy applies to all users of our Website (“You”). By using this Website, you acknowledge you have read and understood this policy.

Data Controller

The controller of your Personal Data is: PT PROTOFLEX RETAIL INTERNASIONAL
Address: The Prominence Office Tower, Level 28 Unit C Jl. Jalur Sutera Bar.15 Alam Sutera, Tangerang, Banten, Kota Tangerang, Jawa Barat 15143, Indonesia.
Email: sales@protoflex.id

Information We Collect

We may collect the following types of Personal Data:

• Identity Data: Full name, username or similar identifier.

• Contact Data: Email address, telephone numbers, billing address, delivery address.

• Transaction Data: Details about products/services you have purchased from us, payment details (we may use third-party payment processors; we do not store full credit card details).

• Technical Data: Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.

• Profile Data: Your username and password (encrypted), purchases or orders made by you, your interests, preferences, feedback, and survey responses.

• Usage Data: Information about how you use our Website, products, and services.

• Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity.

How We Collect Your Personal Data

• Direct Interactions: You may give us your Identity, Contact, and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

  • Create an account on our Website;

  • Order our products or services;

  • Subscribe to our service or publications;

  • Request marketing to be sent to you;

  • Enter a competition, promotion or survey; or

  • Give us feedback or contact us.

• Automated Technologies or Interactions: As you interact with our Website, we will automatically collect Technical Data about your equipment, Browse actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. (See our Cookie section below).

• Third Parties or Publicly Available Sources: We may receive Personal Data about you from various third parties such as analytics providers (e.g., Google), advertising networks, and search information providers.

Lawful Basis for Processing Your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances (under GDPR and PDP Law):

• Performance of Contract: Where we need to process your data to perform the contract we are about to enter into or have entered into with you (e.g., to process and deliver your order).

• Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., for website analytics, fraud prevention, direct marketing to existing customers within reasonable limits).

• Consent: Where you have given us explicit consent to process your Personal Data for one or more specific purposes (e.g., to send third-party marketing newsletters). You have the right to withdraw consent at any time.

• Legal Obligation: Where we need to comply with a legal or regulatory obligation that applies to us.

We identify the legal basis we rely on for each purpose for processing your Personal Data.

How We Use Your Personal Data

We use your Personal Data for the following purposes, relying on the appropriate lawful basis:

• To register you as a new customer (Contract)

• To process and deliver your order (Contract, Legitimate Interest)

• To manage our relationship with you (Contract, Legitimate Interest, Legal Obligation)

• To enable you to partake in a promotion or survey (Consent, Legitimate Interest)

• To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (Legitimate Interest, Legal Obligation)

• To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve (Legitimate Interest, Consent)

• To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences (Legitimate Interest)

• To make suggestions and recommendations to you about goods or services that may be of interest (Legitimate Interest, Consent)

• To comply with legal and regulatory obligations (Legal Obligation)

Disclosures of Your Personal Data

We may have to share your Personal Data with the parties set out below for the purposes set out in this policy:

• Third-Party Service Providers: Companies providing IT and system administration services, payment processing, order fulfillment, analytics, marketing services, etc.

• Professional Advisers: Lawyers, bankers, auditors, and insurers providing consultancy, banking, legal, insurance, and accounting services.

• Government Authorities & Regulators: Tax authorities, police, other regulators in Indonesia and other jurisdictions who require reporting of processing activities in certain circumstances.

• Third Parties in Business Transactions: Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

International Data Transfers

As we operate in Indonesia, your Personal Data will be processed in Indonesia. If you are accessing the Website from outside Indonesia (especially from the EEA), your Personal Data will be transferred to Indonesia. For transfers of Personal Data from the EEA to Indonesia (which does not currently have an adequacy decision from the European Commission), we rely on:

• The performance of our contract with you (e.g., to process your order).

• Your explicit consent for such transfers.

• Other mechanisms permitted by GDPR where applicable, such as Standard Contractual Clauses (SCCs) with specific partners if relevant.

We will take reasonable steps to ensure that your Personal Data is treated securely and in accordance with this privacy policy when transferred.

Data Security

We have put in place appropriate technical and organizational security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know.

Cookies and Similar Technologies

Our Website uses cookies to distinguish you from other users, provide a good experience, and improve our site. For detailed information on the cookies we use and the purposes for which we use them see our [Link to your Cookie Policy, if separate, or add details here]. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

Your Data Protection Rights

Under GDPR (and PDP Law where applicable), you have the following rights:

• Right of Access: Request access to your Personal Data.

• Right to Rectification: Request correction of inaccurate or incomplete Personal Data.

• Right to Erasure (‘Right to be Forgotten’): Request erasure of your Personal Data under certain conditions.

• Right to Restrict Processing: Request restriction of processing of your Personal Data under certain conditions.

• Right to Data Portability: Request the transfer of your Personal Data to another party in a structured, commonly used, machine-readable format (where processing is based on consent or contract and is automated).

• Right to Object: Object to processing of your Personal Data based on our legitimate interests or for direct marketing purposes.

• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time.

• Rights Related to Automated Decision Making: The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (we will inform you if we do this).

To exercise these rights, please contact us at sales@protoflex.id. We may need to request specific information from you to help us confirm your identity.

Data Retention

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Children’s Privacy

This Website is not intended for children under the age of [Enter age, e.g., 18] and we do not knowingly collect data relating to children.

Links to Other Websites

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

Changes to the Privacy Policy

We may update this policy from time to time. The latest version will always be posted on this page with an updated effective date.

Right to Lodge a Complaint

You have the right to lodge a complaint at any time with the relevant data protection supervisory authority. For individuals in the EEA, this is the supervisory authority in the EU member state of your habitual residence, place of work, or place of the alleged infringement. We would, however, appreciate the chance to deal with your concerns before you approach the authority, so please contact us in the first instance.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at: sales@protoflex.id