Last updated on October 2022
- What Personal Data Asa Ren might collect about User;
- What Asa Ren might do with that Personal Data; and
- User choices about the Personal Data User provide.
This policy covers products and services in Asa Ren Platform which provided through these platforms such as Asa Ren counselling, DNA Report and any other interactions User may have with Asa Ren by telephone, e-mail, or in person. This policy specifically covers Asa Ren handling of Personal Data relating to identifiable individuals, and does not apply to proprietary business information. Some of Asa Ren product services are provided on behalf of Asa Ren clients, which means Asa Ren client remains primarily responsible for User Personal Data. For instance, Asa Ren may be providing services on behalf of employer or sponsor plan. In these circumstances, Asa Ren may redirect a query about Asa Ren use of User Personal Data to Asa Ren’s client. In this matter, Asa Ren requires the Client to make a written agreement with Asa Ren and the client obtains the consent of each User.
Getting User Consent
As part of using Asa Ren services or interacting with Asa Ren, Asa Ren may collect and process some details about User when User interact with Asa Ren through Asa Ren Platform. When Asa Ren do so, Asa Ren will collect, use or share User Personal Data with User consent for the purposes Asa Ren have informed User of, or as may be otherwise permitted or required by law.
User can withhold or withdraw User consent for Asa Ren to collect, use or share User Personal Data, as long as there are no legal or contractual requirements for Asa Ren to process User information. Depending on the circumstances, however, withdrawal of User consent may impact Asa Ren ability to serve User, or in the case of administering benefits, it may prevent Asa Ren from providing services to Users, so Asa Ren has the right to enforce provisions regarding account deletion.
- Asa Ren is a site and/or application managed by PT Asa Ren Global Nusantara and/or its affiliates that have services in the form of consulting with health advisors/consultants, DNA testing, and selling DNA test kits.
- User is every individual who is eligible according to Asa Ren’s Terms of Service and intends to access Asa Ren Platform.
- Personal Data is information and/or data that could be used to identify you, either alone or in combination with other information.
- Platform is a website and/or mobile apps managed by Asa Ren as updated from time to time.
- Products are goods and services sold by Asa Ren in Asa Ren Platform which consist of DNA test device, and consulting services on DNA test reports.
- Services are services offered by Asa Ren in Asa Ren Platform which consist of DNA laboratorium testing, consultation with counselor/health consultant and other services that may be added to Asa Ren Platform from time to time.
- Aggregate data is different from User's Personal Data. Please note that aggregated data does not contain information about specific User data. Aggregate data is information data about a group of individuals where names and address information are omitted, then the remaining data is combined from User data and then analyzed or evaluated as a whole, so that no particular User can be reasonably identified.
- Anonymous data is any information that Asa Ren have disguised in a way that causes the information to no longer identify the User, either directly or indirectly, and therefore it cannot be categorized as Personal Data.
- De-identification Information, namely information that has been limited to identifying data so that the User's identity cannot be reasonably identified.
- Client is a party that cooperates with Asa Ren to conduct DNA tests on registered Users collectively, including but not limited to the Employer or the planning sponsor, where the client is required to make a written agreement with Asa Ren and the client obtains approval from each User
Where Asa Ren Get User Information
Asa Ren collect Personal Data in the following ways:
- Fill in personal data in order to use the account or other documents used in order to use the Product;
- From User use of Asa Ren's services, programs, websites and mobile apps;
- When User attend a Asa Ren's site or event;
- If User contact Asa Ren with a complaint or query;
- From legally authorized third parties.
Eligibility of User
User warrant that User is an individual who is entitled to make an agreement or to bind themself according to prevailing laws and regulations, is 18 (eighteen) year old or has been married, qualified before the law, and does not under conservatorship. User guarantees the correctness of the Personal Data Information submitted to Asa Ren. Asa Ren has the right to request supporting documents that prove the validity of the User's Personal Data. User's failure to fulfil the guarantee of the correctness of Personal Data information causes Asa Ren to have the right to suspend the account and/or delete the User's account.
Asa Ren will not knowingly collect, use or share Personal Data if User are under the age of majority in User area without the permission of User parent or guardian. If User are underage and want to access our counselling and wellness services, your parent or guardian needs to contact Asa Ren on your behalf. The parent or guardian shall be taken full responsibility to ensure that the information concerning your identity that they provide to Asa Ren Platform is correct. Asa Ren has the rights to request supporting documents that prove the validity of the child’s Personal Data. The failure of the parent or guardian to fulfil the guarantee of the correctness of the Personal Data information results in Asa Ren being entitled to suspend the account and/or delete the child’s sub-account.
Creating Your Account
User must have an account in Asa Ren Platform to access Asa Ren services by registering User e-mail and password to Asa Ren Platform. The account may only be used by the person who has the access into account by entering e-mail and password that has been registered. Asa Ren may periodically send e-mail to User to inform regarding Asa Ren products and services.
If at any time User could not access User account due to User forgot User’s password, User may attempt to reset User’s password by clicking the “forgot password” button on the Asa Ren Platform, then Asa Ren will send a code so that User can reset User’s password. However, if User is unable to access User’s account for other reasons, User may contact Asa Ren and provide Asa Ren with information to verify that the User is owner of the account.
What Information Asa Ren Collect and Why
Asa Ren collection and use of User Personal Data depends on what products and services User chooses and what information User choose to provide to Asa Ren.
Asa Ren may collect and use the following types of information for the following purposes:
- Identity information
Asa Ren may collect User’s name, e-mail, ID card number, telephone number, date of birth, gender, allergies and medical history that User provides in application and data form/consent form for the following purposes:
- To identify and authenticate User,
- To communicate with User, and
- To manage User’s account, including through Asa Ren websites and apps.
- To analyse User’s DNA samples;
- To submit User’s DNA equipment and reports; and
- To increase the satisfaction of using Asa Ren Platform by User.
- Contact information
Asa Ren may collect User e-mail address and telephone numbers for the following purposes:
- To communicate with User and respond to User inquiries,
- To inform to User of news about Asa Ren’s products and services, as well as special promotions, offers or events, and
- To create and administer User account when User register for Asa Ren service, including through Asa Ren websites and apps.
- Transaction information
Asa Ren may collect details about payments to and from User, and other details of products and services User have purchased from Asa Ren, including User’s account numbers, User’s banking information, email linked to User’s electronic transfer, payment information for billing for the following purposes:
- For administering services and auditing, and
- To understand how User use Asa Ren products and services, consist of name, address, telephone number, voucher code, shipping transactions and laboratory activities.
- Biometric information
Asa Ren may collect User’s weight, height, or other similar information provided by User for the following purposes:
- To administer products and services that User have with Asa Ren.
- Lifestyle information and Medical History
Asa Ren may collect information in User’s information regarding tobacco/nicotine use high blood pressure, obesity, diabetes, asthma, and other health-related information for the following purposes:
- To administer products and services that you have with us.
- Interaction information
Asa Ren may collect telephone recordings and transcripts, records of communications (e-mails, letters, online chat etc.) User’s activity in Asa Ren’s Platform for the following purposes:
- To retain a record of User interactions with Asa Ren,
- To communicate with User and respond to User inquiries, and
- To understand any concerns User may have, so that Asa Ren can resolve disputes and improve User experience.
- DNA Report Information
Asa Ren may collect DNA report information from User DNA sample and interpretation of User genetic result for the following purpose:
- Analyse User DNA sample to produce User DNA report information,
- To proceed User DNA result information on Platform based on Asa Ren data protection.
- To create and manage aggregated data, anonymous data and de-identification data in connection with DNA Reports.
However, Asa Ren would not share User DNA report unless to Service Providers based on User consent or required by law, or to Clients or to third parties appointed by Asa Ren.
- Digital interaction information
Asa Ren may collect, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system (including the type of device used) raw data and/or data based on analytical tool, and other technology, related to the devices User use to access Asa Ren Platform for the following purposes:
- To personalize User experience and understand how User use Asa Ren sites and apps,
- To notify User of any relevant issues relating to Asa Ren website or app,
- To measure how Asa Ren apps and websites are performing,
- To identify opportunities for new products/services or improvements to existing ones,
- To promote and market Asa Ren’s products and services to User,
- For the purpose of system or product development and planning, audit and administration, as well as business development and/or Research and developments of new Products and Services,
- To manage and protect the security of Asa Ren’s business, and other Asa Ren sites, apps and services, and
- To fulfil Asa Ren’s legal and regulatory obligations, including to enforce Asa Ren’s legal rights.
- Identity information
Cookie is a data stored in User device which is used to obtain and remember User’s information in Asa Ren Platform. User may obtain cookies by visiting Asa Ren Platform which automatically downloaded to User’s device. User may choose cookie usage which is in Asa Ren Platform. The cookies consist of:
This Cookie supports the use of Asa Ren Platform and enable particular features to improve User experience. For instance, the usage of Functional Cookies to facilitate User for ordering and remembering User’s choice when you move from page to page. Other than that, Functional Cookies may also be used to remember matters such as User’s login information and product and/or services preferences to prevent User to re-enter your information.
This Cookie collects required information to support Asa Ren Platform and allows Asa Ren to improve Asa Ren Platform and identify problems that User facing when visiting Asa Ren Platform. For example, Performance cookies may provide Asa Ren the information regarding how User come to Asa Ren Platform and how User navigate Asa Ren Platform during User’s visit. Asa Ren also uses this cookie to obtain certain statistical and analytical information, such as how many visitors come to Asa Ren Platform or how effective Asa Ren’s advertising.
This cookie is used to collect User information to assist Asa Ren in improving Asa Ren Platform and serve User with targeted advertisements that are relevant to you as user. Asa Ren uses Targeting Cookie in Asa Ren Platform for various marketing initiatives and campaigns.
Third Party Cookie
Asa Ren uses a number of third-party service providers to assist Asa Ren in managing, performing, and increasing Asa Ren advertisements. The parties may determine cookie on Asa Ren to assist Asa Ren in collecting information and providing User the advertisement which according to Asa Ren will be relevant to User. In several cases, this third party may also assist Asa Ren by providing certain statistical and analytical information regarding Asa Ren’s marketing practices. Asa Ren may also share collected information through cookie (and other tracking technologies) with third party to be used in third party analysis and marketing purposes.
By blocking one or more types of cookies may affect the User’s use of the Asa Ren Platform. Asa Ren will update the Cookie terms from time to time. User can visit this page if User wants to stay informed. By reading this provision, User understand that by disabling certain cookie will affect User in using Asa Ren services.
- Functional Cookies
De-identified, Aggregated, and Anonymized Information
Asa Ren may use User Personal Data to generate de-identified, aggregated or anonymized information that does not reveal User’s identity. Asa Ren uses this information to conduct research, compile aggregate data sets, statistics and reports, and to perform analytics on Asa Ren services, service standards, business operations, and trends.
Asa Ren may share de-identified, aggregated or anonymized information with Asa Ren clients for reporting purposes, including usage of our services, and with third party service providers to use in creating marketing materials, case studies and statistical analyses. This allows Asa Ren, its clients and Asa Ren’s respective third-party service providers to understand how Asa Ren are performing, or develop relevant products, services or offers.
Who does Asa Ren share User Personal Data With?
Asa Ren may share User Personal Data with:
- Internal Asa Ren, including the shareholders, the Board of Commissioners, the Board of Directors, and employees appointed for the internal and administrative purposes of Asa Ren.
- Asa Ren affiliates, including the parent company and/or subsidiaries of Asa Ren, including but not limited to third-party service providers who are required to keep your information confidential and secure and are restricted from using or disclosing information for reasons other than performing services on Asa Ren behalf or to comply with legal requirements.
- Asa Ren Partners, in this matter is third parties that cooperate with the appointed Asa Ren whose purpose is limited to educational, research, and social purposes.
- Asa Ren Partners, in this matter is third parties that cooperate with the appointed Asa Ren whose purpose is limited only to commercial.
- Government, regulatory and law enforcement agencies to meet our compliance, regulatory, and risk management obligations or to comply with the law.
- The general public and other users when you post or share comments, blog postings, testimonials, or other similar information on our technology platforms.
Storage of User Information
Asa Ren with its best efforts to protect and secure User's personal information from access, collection, use or disclosure by unauthorized persons and from unlawful processing, accidental loss, destruction and damage or similar risks. However, sending information over the internet is not completely secure. Although Asa Ren will try its best to protect User's personal information, User acknowledges that Asa Ren cannot guarantee the integrity and accuracy of any personal information that User submits through the Asa Ren Platform. Asa Ren and/or its technology provider/vendor may store your Personal Data in its databases located in Singapore. If User are visiting Asa Ren Platform from a country other than Indonesia, your communication through our Platform or any of our services may result in the transfer of information across international boundaries. By using Asa Ren Platform or any of Asa Ren services, User consent to the collection, storage, and processing of User information in Asaren’s database in Singapore.
Retention of User Information
Asa Ren only keep User information as long as it is contractually, operationally or legally necessary. When Asa Ren no longer needs the information, it is either destroyed or de-identified.
Terms of Account Deletion from the Platform
- Account deletion and the information and services therein are permanent and cannot be changed. After successful deletion, you will not be able to login and view your account history and Sub-Accounts again. Deletion of your Account also includes deletion of any Sub-Accounts you have in your Account or vice versa;
- Asa Ren may refuse to delete your Account as long as you still have an ongoing order on the Platform;
- The mechanism for deleting your Account is as follows:
- You can delete your account by pressing the “Delete Account” button in the Settings of Main Account Profile;
- After 30 calendar days of requesting your account deletion, your Account will be permanently deleted, and you will no longer be able to retrieve your information. Before that 30 calendar days, you can still cancel the account deletion by logging or accessing your account again in the Platform;
- You may login and download a copy of your information from the Platform before deleting your account. Once your account has been deleted, you cannot have access using your registered e-mail on Asa Ren Platform.
Asa Ren may delete your account shall there is any violation of Terms of Service. Asa Ren will notify you shall there is any suspicion of violation and/or report of any violation. You may clarify regarding this violation in 7 calendar days since the notification from Asa Ren, shall you fail to clarify on the certain times and/or your clarification does not meet Asa Ren’s satisfaction, Asa Ren entitled to delete your account 30 calendar days after notification.
Asa Ren uses reasonable physical, technological, organizational and contractual safeguards, appropriate to the sensitivity of the information, to protect Personal Data in Asa Ren possession or under Asa Ren control, from unauthorized access, disclosure or use. Asa Ren is committed to its best efforts to carry out proper security of User's personal data information to protect User's personal data information. As an implementation of the implementation of security measures, that the security measures taken by Asa Ren are in accordance with the AWS System which can be seen on the https://aws.amazon.com/compliance/resources/ page
Accessing User Information
When requested in writing, Asa Ren will inform User of the existence, use, and disclosure of User Personal Data that Asa Ren maintain. Asa Ren may not be able to provide User with all the information User request, depending on the circumstances, and there may be a charge for copies of User Personal Data.
Correcting User Information
Asa Ren will make reasonable efforts to keep User information accurate and up-to-date. If a change or correction is required, let Asa Ren know immediately via e-mail by including details of changes in User information along with supporting evidence. Asa Ren will make appropriate updates needed to keep things running smoothly. Asa Ren can review User Personal Data by looking at the correspondence Asa Ren send to User, through User online accounts with Asa Ren, or by requesting access to User Personal Data, as described above. User warrant that all information provided to Asa Ren are correct. Asa Ren has the right to request supporting documents that prove the validity of the User's Personal Data. User's failure to fulfill the guarantee of the correctness of Personal Data information causes Asa Ren to have the right to suspend the account and/or delete the User's account.
How Long We Keep Your Information Data
Asa Ren retain User information for as long as necessary, for example, to comply with a contractual relationship with User or to provide Asa Ren services to User. Where Asa Ren do not need User information to provide services to User, Asa Ren only retains it for as long as Asa Ren have a legitimate business purpose in storing the data, as permitted by applicable law. Asa Ren may retain User data for five (5) years (or longer if necessary) Asa Ren’s legal obligations, or if necessary to file, enforce or defend a lawsuit. Once User have discontinued use of Asa Ren Platform and the retention period of five (5) years has elapsed, Asa Ren store User information in an aggregated and anonymous form. The information is not identifying Personal Data may be stored for an indefinite period of time for analytical purposes. In addition, Asa Ren do not sell or rent any of User Personal Data or use User DNA Report for marketing purpose or advertising without User consent during and after the period above.
How Asa Ren Secure User Information
Asa Ren will provide security to protect and secure all User Personal Data in Asa Ren Platform according to prevailing laws and regulations.
Asa Ren restricts access to its personnel, affiliates or representatives. Asa Ren limits access to User information only to authorized parties based on their functions and job descriptions. Asa Ren also requires the appointed party to implement and maintain User Personal Data information both administratively, physically and technically.
Please kindly taking into account that User also responsible to keep the confidentiality of User Personal Data, including User’s e-mail, username, and password in Asa Ren Platform. If there is an alleged misuse in User account without User knowledge and consent, please inform the allegation to Asa Ren. Asa Ren will coordinate and take necessary actions to restore User account.
Receiving Promotional Advertisement
User may choose to or not to receive any promotional e-mail from Asa Ren regarding Asa Ren products and/or services by providing Asa Ren User consent. Asa Ren will only send User promotional e-mail according to your consent.
User may refer other party to Asa Ren by entering their e-mail address. User warrant that the party who provides User with their e-mail address has granted User consent to communicate with Asa Ren. Thus, Asa Ren may send them any information regarding Asa Ren Platform.
Asa Ren will provide its best effort in order that the use of Asa Ren Platform is protected from disturbances such as including but not limited to virus and malware. Asa Ren will notify the User in writing in the event of a system failure and/or failure in connection with the processing of the User's personal data no later than 14 days after the discovery of the disturbance and/or failure.
User Personal Data After Deletion of User Account
If User have feedback regarding User concern of Data Protection should be referred to Asa Ren Legal Officer at email@example.com. Every complaint will be received by Asa Ren. After that Asa Ren Legal Officer would review and assess the complaint or feedback with the result of evaluation based on General Data Protection Regulation or applicable laws and regulations.