Please read this Privacy Policy carefully before you start using Our Platform, as these rules apply to your use of Our Platform.

1. General Provisions
   The protection of Personal Data is of utmost importance to PT Partner Impian Milenial (“We” or “Schoters”). We are committed to protecting and respecting the privacy of users (“You” or “User”) when accessing and using the applications, websites (www.schoters.com/id/ and other websites We manage), features, technology, content, and products We provide (hereinafter collectively referred to as “Platform”).
   This Privacy Policy sets out the basic foundation regarding how We collect, store, use, process, control, transfer, disclose, and protect your Personal Data (as defined below). We process your Personal Data as long as you provide consent and it is necessary to fulfill the purpose of its acquisition and collection, or as required by applicable laws and regulations. This Privacy Policy applies to all users of the Platform, unless stipulated in a separate Privacy Policy. Please read Our Privacy Policy carefully so that you can understand Our approach and methods in using such information.
   If you are under 18 (eighteen) years old, a user with special needs, and/or under guardianship, then you need to discuss and must obtain consent regarding this Privacy Policy with your parents and/or guardian.
   
   By visiting, using services, or registering an Account on Our Platform, You and/or your parents, guardians, or custodians (as relevant) accept and agree to the approaches and methods outlined in this Privacy Policy.
2. Personal Data We May Collect
   We collect information that identifies or can be used to identify, contact, or locate an individual or device associated with such information (“Personal Data”). Personal Data includes but is not limited to name, address, date of birth, phone number, email address, User’s phone number, bank account and credit card details, gender, identification (including KTP, SIM, Passport) or other officially issued government identification. In addition, for other information, such as personal profiles, and/or unique identification numbers, which are linked or combined with Personal Data, such information is also considered Personal Data. The Personal Data we collect may be provided by You directly or by third parties (for example: when you register or use the Platform, when you contact our customer service, or otherwise when you provide Personal Data to Us). We may collect information in various forms and for various purposes (including purposes permitted by applicable laws and regulations).
   We may collect Personal Data in the form of:
   • Personal Data you provide. You can provide information through electronic forms on Our Platform or by corresponding via phone, email, and so on. This information includes information you provide including but not limited to when registering on Our Platform, subscribing to Our services, searching for products, participating in online discussions, webinars or other social media functions on Our Platform, participating in competitions, promotions, or surveys, interacting with Us through external services or applications such as forms, Instagram, Zoom Meeting, Google Form or Youtube, when you report problems through Our Platform, and when you interact with Us offline. We may ask you to verify the information you provide, to ensure the accuracy of the information.
     If you register on Our Platform by using and/or linking your social media accounts such as Facebook or Google, We may access Personal Data you have provided to such social media providers in accordance with the social media provider’s policy and thereafter We will manage and use such Personal Data in accordance with this Privacy Policy.
   • Personal Data We collect. For each of your visits to Our Platform, We may automatically collect the following information:
     • Technical information, including but not limited to the Internet Protocol (IP address) used to connect your computer or device to the internet, your login information, the type and version of browser used, time zone settings, type and version of browser plug-ins, operating system and Platform;
     • Information about your visit, including but not limited to a complete list of Uniform Resource Locators (URLs) visited to, through, and from Our Platform (including date and time); transaction data such as purchase and payment details; products you viewed or searched for; interactions on the application including but not limited to page response times, download problems, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse movements), methods used to leave the site, and phone numbers used to contact Our customer service;
     • Your score data, including but not limited to your exam results obtained through the Platform, as well as other academic data.
   • Information We receive from other sources. We may receive information if you use other sites We operate or other services We provide. We also work with third parties (including but not limited to, for example, referral programs, business partners, sub-contractors in technical services, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies) (“Our Partners”) and may receive information from them. We will take reasonable steps to verify the information We obtain from other sources in accordance with Applicable Regulations. Applicable.
3. Purposes of Personal Data Use
   We may use and/or process Personal Data that We have received for the following purposes:
   • Personal Data of Platform users. We will use and/or process this information:
     • to identify and register you as a Platform user, and to administer, verify, delete, or manage your Account on the Platform;
     • to assist Service Providers in providing certain services on the Platform that you wish to use;
     • to verify the linking of your Schoters Account, in case you link your Schoters account with other applications or platforms;
     • to process and facilitate payments you make for product purchases or service subscriptions within the Platform through payment channels available on the Platform;
     • to carry out Our obligations in providing information, products, and services to you, including but not limited to information about Platform updates or services on the Platform;
     • to provide information related to other products and services We offer to provide you, or allow third parties to provide you, information about products and services We believe may be of interest to you. If you are an existing User, We may contact you by phone, text message, email or other means with information about Our products and services;
     • to notify you about changes to Our products, services or offerings;
     • to ensure that the content of Our Platform is presented in the most effective way for you;
     • to manage and process all forms of points, rewards, loyalty points, or similar items that you receive when using the Platform;
     • to monitor and analyze user activity, behavior, and demographic data including habits and responsiveness of service providers for various services available on the Platform; and
     • to maintain, develop, test, improve, and personalize the Platform to meet your needs and preferences as a User.
   • Personal Data of Service Providers. We will use this information:
     • to identify and register you as a Service Provider on the Platform, and to administer, verify, delete, or manage your account on the Platform;
     • to enable the provision of services by Service Providers to Platform Users;
     • to process payments to Service Providers for the provision of services to Platform users by Service Providers;
     • to manage and process bonuses that Service Providers may receive when providing services on the Platform;
     • to process and respond to Platform user suggestions for services that Service Providers have provided;
     • to carry out Our obligations in providing information, products, and services to Service Providers (including but not limited to information about Platform updates or services on the Platform);
     • to monitor and analyze user activity, behavior, and demographic data including habits and responsiveness of service providers for various services available on the Platform;
     • to provide reports in connection with the services that Service Providers provide through the Platform;
     • to maintain, develop, test, improve, and personalize the Platform to meet your needs and preferences as a service provider; and
     • to monitor and analyze user activity, behavior, and demographic data including habits and responsiveness of Service Providers for various services available on the Platform.
   • Information We collect. We will use this information:
     • to administer and develop Our services, Platform and internal operations, including troubleshooting, data analysis, testing, research, and other statistical and survey purposes;
     • to improve Our Platform so that content is ensured to be presented in the most effective way for Users;
     • to enable Users to participate in Our interactive service features, when Users wish;
     • as part of efforts to ensure the safety and security of Our Platform;
     • to measure and understand the effectiveness of advertising We do to Users and other parties, and to present advertisements for products and services relevant to Platform Users;
     • to provide input and recommendations to Users and other users on Our Platform regarding products and services that may be of interest to You and them.
   • Information We receive from other sources. We may combine information We receive from other sources with information you provide and information We collect. We may use this information or combined information for the purposes set out above (depending on the type of information We receive).
   • Information about third parties you provide to Us. You may provide us with Personal Data relating to other third-party individuals (including Personal Data relating to your spouse, family members, friends, or other individuals, both Users and non-Users of the Schoters Platform). You will, of course, need their consent first to do so – please refer to the “Acknowledgment and Consent” section below for more information.
     If you use social features on our Platform, you may share the phone numbers of Our Users stored in your device’s contact list or address book application so that We can help facilitate you in connecting you with your friends or acquaintances who use those social features.
   • Any purpose other than those mentioned above, which We will further notify you of at the time of obtaining your consent at a later date.
4. Disclosure of Personal Data
   We may disclose your relevant Personal Data such as name and grade level through the Platform and/or Our social media accounts for the purpose of announcements, competition results and/or other activities organized by Us.
   • We may also share or disclose your Personal Data with members of Our corporate group, which includes branches and subsidiaries, as well as the main parent company and its subsidiaries (“Affiliates”), for purposes including but not limited to (i) the implementation of support for the provision of the Platform by Affiliates, (ii) the implementation of Our business activities by Affiliates, and (iii) data processing by Affiliates. The use and processing of Personal Data received by Affiliates from Us shall be carried out in accordance with this Privacy Policy and applicable laws and regulations.
   • We may share your Personal Data with third parties for the purposes as follows and to the extent permitted by applicable laws and regulations, including:
     • Business partners, agents, vendors, and sub-contractors in the performance of contracts We enter into with them or You in connection with the provision of the Platform or other functionalities related to your use of the Platform;
     • Advertisers and advertising networks that require data to select and offer relevant advertisements to You and other users. We do not disclose identifiable individual information, but We may provide them with aggregated information about Our users (e.g., information that 500 men under 30 have accessed their advertising link on a given day). We may also provide aggregated information to help advertisers reach a specific target audience (e.g., women in Central Jakarta). We may use the personal data We collect to fulfill advertisers’ requests by displaying their advertisements to that target audience;
     • Analytics and search engine providers who assist Us in improving and optimizing Our Platform;
     • Government, in the event that We are ordered, directed, requested, or permitted by competent government agencies, for purposes as stipulated in government policies and/or applicable laws and regulations;
     • Law enforcement agencies (including but not limited to police, prosecutors, and judicial institutions), in cases where it is needed for legal proceedings between Us and You, or You and other third parties, whether related to your use of the Platform or not.
   • We may disclose your Personal Data to third parties in the event of a corporate action occurring to Our company:
     • In situations where We sell or buy companies and/or assets, We may disclose data to prospective buyers or sellers of such companies or assets;
     • If We or Our parent company or substantial assets related thereto are acquired by a third party, then Personal Data held about Our customers will be one of the transferred assets;
     • If We are under an obligation to disclose or share data to comply with legal obligations and other agreements; or to protect the rights, property, or safety of Us, Our customers, and others. This includes exchanging information with other companies and organizations for the purpose of fraud protection and credit risk reduction.
5. Disclosure of Personal Data will only be carried out on a limited and reasonable basis and subject to applicable laws and regulations.
   If, for any reason, we need to disclose your Personal Data to a third party, we will endeavor to ensure that such third party and our Affiliates keep your Personal Data in accordance with applicable laws and regulations so that it remains secure from unauthorized access, collection, use, disclosure, processing or similar risks and store your Personal Data only for as long as your Personal Data is needed to achieve the purposes mentioned in this section.
   In the event of disclosure of Personal Data to foreign parties, we will ensure that such parties will process Personal Data with policies that have a level of protection equivalent to or better than applicable laws and regulations.
6. Storage of Personal Data
   All Personal Data you provide to Us is stored on a secure network. All payment transactions on the Platform will be encrypted. By submitting your Personal Data on the Platform, you agree to the transfer, storage, and processing that occurs on Our Platform. We will take reasonable steps necessary to ensure that such Personal Data is treated securely and in accordance with this Privacy Policy and Applicable Regulations.
   To the extent permitted by relevant laws and regulations, all Personal Data you provide will be stored by Us: (i) as long as you remain a user of Our Platform and (ii) when the retention period begins from the date on which you stop using Our Platform and/or from the request for deletion of your account and Personal Data; or (iii) in accordance with the original purpose of the collection of such Personal Data.
   Deletion of Personal Data
   We will only delete your Personal Data if:
   • You no longer use our Platform, evidenced by a request for account deletion;
   • You submit a request for partial or complete deletion of your Personal Data;
   • There is a court decision that has permanent legal force or an order from a competent official to delete your Personal Data.
7. The deletion of your Personal Data does not remove Our obligation to store your Personal Data for the purposes and within the time required by applicable laws and regulations.
   To the extent permitted by relevant laws and regulations, your Personal Data may be stored or processed outside Indonesia for one or more purposes mentioned in this Privacy Policy. We will always endeavor to maintain the security of your Personal Data and will only transfer your Personal Data outside Indonesia in accordance with applicable laws and regulations.
8. Destruction of Personal Data
   We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected as set out in this Privacy Policy, or as required by applicable laws and regulations. If the data is no longer needed for legitimate processing or storage purposes, we will destroy the Personal Data in accordance with secure procedures. Destruction of Personal Data will be carried out in the following situations:
   • Retention period has ended: Personal Data that has reached the storage limit set by internal policies or laws and regulations will be destroyed in a secure manner.
   • Request from the data subject: You, as the data subject, have the right to request the destruction of Personal Data that has been processed, unless there is a legal obligation requiring us to store the data.
   • Legal or regulatory obligations: We are required to destroy Personal Data based on applicable laws and regulations or valid legal decisions.
9. The destruction process will be carried out in a way that ensures Personal Data cannot be recovered and is completely inaccessible by any party.
10. Security of Your Personal Data
    The confidentiality of Personal Data is a priority for Us and Our Affiliates. We will always take appropriate legal, organizational, and technical measures to ensure that your Personal Data is safe and protected. Any processing of your Personal Data will only be carried out in accordance with this Privacy Policy and applicable laws and regulations.
    Please note that the transmission of information via the internet is not completely secure. However, We will do Our best to protect such Personal Data. We cannot guarantee the security of data transmitted to Our Platform; the risk of any transmission is your responsibility. Once We receive your Personal Data, We will use strict procedures and security features to prevent unauthorized access.
    You are responsible for (i) maintaining the confidentiality of your account, including passwords and payment details, from anyone and (ii) maintaining and ensuring the security of your device used to access and use the Platform.
    In situations where We provide a One Time Password (OTP) (or you choose) a password that allows you to access certain parts of Our Platform, you are responsible for maintaining the confidentiality of this password. We ask and urge you not to share your password with anyone.
11. Your Rights
    • You have the right to be given clear, transparent, and easily understandable information about how We use your personal data and your rights. Therefore, We provide you with information in this Privacy Policy.
    • You may request the deletion of Personal Data and/or the destruction of your Personal Data on the Platform or withdraw your consent for any or all collection, use, or disclosure of your Personal Data by giving us reasonable written notice through the contact details listed in this Privacy Policy. Depending on the circumstances and nature of your request, you must understand and acknowledge that after such withdrawal of consent or deletion request, you may no longer be able to use the Platform. The withdrawal of your consent may result in the termination of your Account or your contractual relationship with us, with all rights and obligations arising fully to be fulfilled. Upon receiving notice to withdraw consent for the collection, use, or disclosure of your Personal Data, We will inform you of the possible consequences of such withdrawal so that you can decide whether or not you still wish to withdraw your consent.
    • You may request Us to access and/or correct, complete, rectify or update your Personal Data in our possession and control, by contacting us through the contact details provided below. Please note that all requests will undergo a careful screening and verification process and will only be processed by us if you have submitted adequate proof of identity to access, correct or request a copy of such data. We reserve the right to refuse requests to access, or to correct, some or all of your Personal Data if permitted or required under Applicable Laws and Regulations.
    • You have the right to obtain a copy of your Personal Data from our database. This only applies to data you provide, where processing is based on a contract or your consent. For more details, please contact us at the details below.
    • You may request to receive or transfer your Personal Data to another organization in a form that is structured and/or in a commonly used or machine-readable format, where your Personal Data is processed based on your consent or as part of the performance of a contract, as long as the systems used can communicate securely in accordance with the principles of Personal Data Protection under applicable laws.
    • Rights related to automated decision-making. We do not adopt automated decision-making technology that has legal or other significant impacts on you. Although We currently do not carry out such processes, you still have the following rights, should the situation change in the future:
      • Human Intervention: You have the right to request human intervention in any decision-making process, ensuring that decisions are not fully automated.
      • Express Views: You have the right to express your views and to be heard in the decision-making process.
      • Explanation of Decisions: You have the right to request an explanation of the logic behind automated decisions and the potential impact that may arise from them.
      • Challenge Decisions: You have the right to challenge decisions based on automated processing and request a review of those decisions.
    • And in certain circumstances, you have the right to request restriction of our data processing or object to the Processing of your Personal Data.
    • If you feel that your data privacy rights have been violated or you have suffered losses due to the unlawful processing of your Personal Data, you have the right to lodge a complaint directly with Us or the relevant data privacy authority in accordance with Applicable Laws and Regulations.
12. Our Platform may, from time to time, contain links to and from the websites of Our partner networks, advertisers, and other affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We are not responsible or liable for these policies. Please check these policies before you submit any information to these websites.
13. Cookies Policy
    When you use the Platform, We may place a number of cookies on your browser. Cookies are small digital files containing letters and numbers that We store on your device’s browser or hard drive with your consent. Cookies contain information that is transferred to your device’s hard drive.
    Cookies may be used for the following purposes: (i) enabling certain functions, (ii) providing analytics, (iii) storing your preferences; and (iv) enabling the delivery of advertisements and behavioral advertising. Some of these cookies will only be used if you use certain features, or choose certain preferences, while some other cookies will always be used.
    We use cookies for the following reasons:
    • Cookies are needed for the operation of Our Platform. This includes, for example, cookies that allow you to enter a secure area of Our Platform, use a shopping cart, or use electronic billing services;
    • Cookies allow Us to recognize and count the number of visitors and see how visitors move around Our Platform when they use it. This helps Us improve the way Our Platform works, for example, by ensuring users find what they are looking for easily;
    • Cookies are used to recognize you when you return to Our Platform. This allows Us to personalize Our content for you, greet you by name, and remember your preferences (for example, your language or region choice);
    • Cookies record your visit to Our Platform, the pages you have visited, and the links you have followed. We will use this information to make Our Platform and the advertisements placed on it more relevant to your interests. We may also share this information with third parties for that purpose.
14. Please note that third parties (including, for example, advertising networks and external service providers such as web traffic analytics services) may also use these cookies, over which We have no control. These cookies tend to make Our Platform and the advertisements displayed on it more relevant to your interests, and improve the performance of Our Platform.
    You can delete Cookies by performing the clear data function on your mobile app or web browser, which allows you to reject the setting of all or some Cookies. However, you may not be able to access all or part of Our Platform.
15. Acknowledgement and Consent
    You understand and agree that this Privacy Policy is an agreement in electronic form. Your action of checking the box stating “I agree to the Privacy Policy” or any other method that We may implement when creating your Account constitutes your active consent to bind yourself in an agreement with Us, so that the validity of the Privacy Policy is legally valid and binding and continues to apply throughout your use of the Platform.
    By agreeing to the Privacy Policy, You and/or your parents, guardians or custodians (in the event that you are under 18 (eighteen) years old) acknowledge that you have read and understood this Privacy Policy and agree to all its provisions. In particular, you agree and give consent to Us to collect, use, share, disclose, store, transfer, and/or process your Personal Data in accordance with this Privacy Policy.
    In the event that you provide Personal Data relating to other individuals (for example, Personal Data relating to your spouse, family members, friends, or other parties) to Us, then you represent and warrant that you have obtained the consent of such individuals to, and hereby agree on behalf of such individuals to, Our collection, use, disclosure, and processing of their Personal Data.
    We are not responsible for the accuracy of the Personal Data We obtain and therefore you are obliged to always change, correct, and/or update your Personal Data.
16. Marketing Material
    We and Our Partners may send you and/or your parents, guardians or custodians direct marketing, advertisements, and promotional communications via push-notifications, messages through the Platform, post, phone calls, short message service, email and/or other messaging applications (“Marketing Material”) if you have agreed to subscribe to Our mailing list, and/or agreed to receive marketing and promotional materials from Us. You may opt out of receiving such marketing communications at any time by contacting Us through the contact details listed in this Privacy Policy. Please note that if you choose to opt out, We may still send you non-promotional messages, such as receipts or information about your Account.
17. Anonymous Data
    We may create, use, license or disclose Personal Data available on the Platform, provided that, (i) all identifying information has been removed so that the data, whether alone or combined with other available data, cannot be linked to or associated with or cannot identify an individual, and (ii) similar data has been aggregated so that the original data forms part of a larger data set.
    The techniques mentioned above also apply if you (i) request the deletion of your account and Personal Data, (ii) withdraw permission to use our services and Platform, or (iii) when you stop using our Platform. We will destroy any of your Personal Data after a minimum of 5 (five) years or a longer period according to internal policy or as required by applicable regulations, since you performed one of these three possibilities, if the Personal Data is no longer needed for the services or purposes mentioned in this Privacy Policy, and if We no longer have a legal or business purpose to store your Personal Data.
18. Changes in Privacy Policy
    Any changes We make to Our Privacy Policy in the future will be published through this page and, if needed and/or there are material changes, We will notify you via email. Please revisit this page from time to time to see any updates or changes to Our Privacy Policy.
    If permitted by statutory provisions, continued use of our services and Platform or explicit consent will be considered as your consent and acceptance of the changes We make to this Privacy Policy.
19. Limitation of Liability
    To the extent permitted by applicable laws and regulations, You hereby agree to release, indemnify, hold harmless, and defend Us, including any officers, directors, employees, agents, Affiliates from and against any and all demands, suits, claims, losses, liabilities, obligations, costs, damages, and expenses (including but not limited to legal fees and indemnity expenses) arising directly or indirectly from:
    • any risk resulting from Personal Data being intercepted, eavesdropped, stolen, accessed, stolen, disclosed, altered, or destroyed by unauthorized parties due to your fault;
    • any risk resulting from the processing of Personal Data that is not in accordance with this Privacy Policy and/or applicable laws and regulations but not due to Our fault;
    • all risks arising from your personal negligence and/or errors in maintaining the security and confidentiality of your Personal Data;
    • any risk arising from the use of any media and/or applications you use to disclose and/or store your Personal Data, such as storage services.

How to Contact Us
If you have any questions regarding this Privacy Policy or you wish to access and/or correct your Personal Data, please contact Us at ask@schoters.com.