Last updated on September 2023
- Personal data Users collected by Asa Ren
- Use of User's Personal Data; and
- User's Choice regarding the Personal Data that the User provides.
This policy covers Asa Ren products and services provided through this Platform such as counseling services, Asa Ren DNA reports and other interactions that Users may have with Asa Ren via telephone, e-mail, or in person. This policy specifically covers Asa Ren's handling of Personal Data relating to identifiable individuals, and does not apply to proprietary business information.
Get User Consent
As part of using Asa Ren's services or interacting with Asa Ren, Asa Ren may collect and process some details about Users when Users interact with Asa Ren through the Asa Ren Platform. When Asa Ren does so, Asa Ren will collect, use, or share User Personal Data with the User's consent for the purposes Asa Ren has informed the User, or as permitted or required by law.
Users 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. However, depending on the situation, withdrawing the User's consent may affect Asa Ren's ability to serve the User. This can prevent Asa Ren from providing services to Users, so Asa Ren has the right to enforce provisions regarding service termination or discontinuation.
- Asa Ren is a site and/or application managed by PT Asa Ren Global Nusantara and/or its affiliates that have services in health and lifestyle support.
- Personal Data is information and/or data that can be used to identify Users, either independently or in combination with other information, either directly or indirectly through electronic or non-electronic systems.
- Platform is a website and/or mobile application managed by Asa Ren which is updated from time to time.
- Products are goods and services sold by Asa Ren in the Asa Ren Platform.
- Services are services offered by the Asa Ren Platform which consist of laboratory testing services for DNA, consultation with advisor/health worker such as doctor and other services that may be added to the Asa Ren website and/or application from time to time.
- Aggregated data is different from User Personal Data. Please note that aggregate data does not contain information regarding specific User data. Aggregate data is data information about a group of individuals where name and address information are omitted, then the remaining data is combined from User data and then analyzed and evaluated as a whole, so that no particular User can be identified fairly.
- Anonymous data is any information that we have disguised in a way that results in that information no longer being able to identify the User, either directly or indirectly, and therefore it cannot be categorized as Personal Data.
- De-identification information, namely information that has been restricted to identify data so that the User's identity cannot be identified fairly.
- Client is a party that cooperates with Asa Ren to carry out a DNA test on Users who are registered collectively, including but not limited to Employers or planning sponsors, where the client is required to make a written agreement with Asa Ren and the client obtains approval from each User.
Where Asa Ren Gets User Information
Asa Ren collects Personal Data in the following ways:
- When the User installs the Asa Ren application and registers the User;
- When Users buy Asa Ren service products and fill out the consent form;
- Through integration of the Asa Ren application with other third party applications;
- fill in personal data in order to use accounts or other documents used in the framework the use of Product;
- From the User's use of Asa Ren's services, programs, sites and mobile applications;
- When User access site or partitioned pass in the Asa Ren event;
- If the User contacts Asa Ren with a complaint or question;
- Legally valid third party.
The user guarantees that the user as a user is an individual who has the right to make a deal or to bind themselves based on applicable laws and regulations, are 18 (eighteen) years old or meet the requirements of being legally competent, and are not under guardianship. The user guarantees the correctness of the Personal Data information submitted to Asa Ren. Asa Ren has the right to request supporting documents proving the validity of User's Personal Data. The User's failure to fulfill the guarantee of correctness of Personal Data information results in Asa Ren having the right to suspend the account and/or delete the User's account.
Asa Ren does not collect, use, or share Personal Data if the User is under the age of majority in the User's area without the permission of the User's parent or guardian. If the User is underage and wants to access Asa Ren's consultation and health services, the User's parent or guardian needs to contact Asa Ren on behalf of the User. Parent or guardian responsible fully to ensure that the information regarding User identity that they provide to the Asa Ren Platform is correct. Asa Ren has the right to request supporting documents proving the validity of the child's Personal Data. The failure of a parent or guardian to fulfill the guarantee of correctness of Personal Data information results in Asa Ren having the right to suspend the account and/or delete the child's sub-account.
Creating a User Account
Users must have an account on the Asa Ren Platform to access Asa Ren services by registering an email and password on the Asa Ren Platform. The account can only be used by people who have access to the account by entering the registered email and password. Asa Ren may periodically send email to Users to inform them about Asa Ren's products and services.
If at any time the User cannot access the User account because the User has forgotten the password, the User can try to reset the User's password by clicking the "forgot password" button on the Asa Ren Platform, then Asa Ren will send a code so that the user can reset the password. User. However, if the User cannot access the User's account for other reasons, the User can contact Asa Ren and provide Asa Ren information to verify that the User is the owner of the account.
What Information Asa Ren Collects and Why
The collection and use of User Personal Data by Asa Ren depends on what products and services the User chooses and what information the User chooses to provide to Asa Ren.
Asa Ren may collect and use the following types of information for the following purposes:
- Identity Information
Asa Ren was able to gather User’s full name, email, Citizen ID (KTP), telephone number, date of birth, gender, domicile address, selfie, allergies and medical history that the User provides in the application and the data form/consent form for the following purposes:
- To identify and authenticate Users;
- To communicate with Users,
- To manage User accounts, including through the Asa Ren website and application;
- To analyze the User's DNA sample;
- To send User's equipment and DNA reports; And
- To increase the satisfaction of using the Asa Ren Platform by Users.
- Contact Information
Asa Ren can collect, address, email, and the User's telephone number for the following purposes:
- To communicate with Users and answer User questions,
- To inform Users about news about Asa Ren's products and services, as well as promotions, offers or events, and
- To create and manage User accounts when Users register for Asa Ren services, including through the Asa Ren website and application.
- Transaction Information
Asa Ren can collect details about payments to and from Users, and other details of the products and services that Users have purchased from Asa Ren, including User account numbers, User banking information, e-mails linked to User electronic transfers, payment information for billing , for the following purposes:
- For service management and audits, and
- To understand how Users use Asa Ren's products and services, consisting of: name, address, telephone number, voucher code, shipping transactions and laboratory activities.
- Biometric Information
Asa Ren may collect information about the User's weight, height, or other similar information provided by the User for the following purposes:
- To manage the products and services that Users have with Asa Ren; and
- For research purposes.
- Lifestyle and Health History Information
Asa Ren can collect User information in terms of tobacco/nicotine use, high blood pressure, obesity, diabetes, asthma,drug consumption data, medical history, , User activities such as footsteps, body temperature, sleep cycles and other health-related information for the following purposes:
- To manage the products and services that Users have with Asa Ren;
- For Service improvement; And
- For research purposes.
- Interaction Information
Asa Ren may collect telephone records and transcripts, communication records (e-mails, letters, online chats, etc.), User activity in the application for the following purposes:
- To keep a record of the User's interaction with Asa Ren,
- To communicate with Users and respond to User inquiries,
- To understand any problems the User may have, so that Asa Ren can resolve disputes and improve the User experience.
- DNA Report Information
Asa Ren can collect DNA report information form sample User's DNA and interpretation of User's genetic results for the following purposes:
- Analysis Sample User DNA to generate User DNA report information.
- For continue the User's DNA result information on the Platform based on Asa Ren data protection.
- To create and maintain aggregated data, anonymized data and de-identified data in respect of DNA Reports.
However, Asa Ren will not disseminate User DNA reports except to Service Providers based on User approval 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, setting time zone and location Puseful, 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 technologies, related to the devices that Users use to access the Asa Ren Platform for the following purposes:
- To personalize the User's experience and understand how the User uses the Asa Ren site and application,
- To notify Users about any relevant issues related to the Asa Ren site or application,
- To measure the performance of the Asa Ren application and site,
- To identify opportunities for new products/services or enhancements to existing ones,
- Promote and market Asa Ren products and services to Users,
- For the purpose of system or product development and planning, auditing and administration, as well as business development and/or Research and development of new Products and Services,
- Manage and protect the security of Asa Ren's business, and other Asa Ren's sites, apps and services, and
- Fulfill Asa Ren's legal and regulatory obligations, including to enforce Asa Ren's legal rights.
- Identity Information
- Functional Cookies
Cookies support the use of the Asa Ren Platform and enables certain features to enhance User experience. For example, use of Functional Cookies to facilitate the User's ordering and remembering the User's choices when the User moves from page to page. Besides that, Functional Cookies can also be used to remember things like information login User and User product and/or service preferences to avoid the User having to re-enter User information.
- Performance Cookies
- Targeting Cookies
Cookies are used to collect User information to assist Asa Ren in improving Asa Ren's Products and/or Services, as well as serving Users with targeted advertisements that are relevant to Users. Asa Ren uses Targeting Cookie on the Asa Ren website and/or app for various marketing initiatives and campaigns.
- Cookie third party
Asa Ren uses a number of third-party service providers to help Asa Ren manage, execute, and improve Asa Ren's advertising. These parties may specify Cookie on Asa Ren to help Asa Ren collect information and provide Users with advertisements that Asa Ren thinks will be relevant to Users. In some cases, these third parties may also assist Asa Ren by providing certain statistical and analytical information regarding Asa Ren's marketing practices. Asa Ren may also share the information it collects via Cookie (and other tracking technologies) with third parties for use in third party marketing and analytics purposes.
Blocking one or several types of cookies can affect the use of the Asa Ren Platform by Users. Asa Ren will update the terms Cookie from time to time. Users can visit this page if users want to stay informed. By reading these terms, the User understands that by not activating certain cookies will impact on User in using Asa Ren's services.
- Functional Cookies
De-identified, Aggregated, and Anonymous Information
Asa Ren may use User Personal Data to generate de-identification, aggregated or information anonymous which does not reveal the 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's services, service standards, business operations, and trends.
Asa Ren may share de-identified, aggregated, or other information anonymous with Asa Ren clients for reporting purposes, including the use of Asa Ren services, and with third party service providers for use in creating marketing materials, case studies, and statistical analysis. This enables Asa Ren, its clients, and Asa Ren's respective third party service providers to understand Asa Ren's performance, or develop relevant products, services, or offers.
To Whom Does Asa Ren Share User Personal Data?
Asa Ren can share User Personal Data with:
- Internal Asa Ren, including shareholders, the Board of Commissioners, Directors, and employees appointed for internal and administrative purposes of Asa Ren.
- Affiliates of Asa Ren, including parent companies and/or subsidiaries of Asa Ren, including but not limited to third party service providers who are required to maintain the confidentiality and security of User information and are prohibited from using or disclosing information for reasons other than carrying out services on behalf of Asa Ren or for comply with legal requirements.
- Asa Ren Partners, in this case, are third parties who work closely with Asa Ren whose purpose is limited to educational, research, social purposes.
- Asa Ren partners, in this case, are third parties who work with Asa Ren whose purpose is limited to commercial purposes.
- Governments, regulatory and law enforcement agencies to fulfill our compliance, regulatory and risk management obligations or to comply with the law.
- The general public and other users when you upload or share comments, posts blog, testimony, or other similar information on our technology platforms,
Information Storage User
Asa Ren does its best to protect and secure User's personal information from access, collection, use or disclosure by unauthorized persons and from processing that violates the law, accidental loss, destruction and damage or similar risks. However, sending information via the internet is not completely secure. Although Asa Ren will try its best to protect User's personal information, Users acknowledge that Asa Ren cannot guarantee the integrity and accuracy of any personal information that Users send through the Asa Ren Platform. Asa Ren and/or its technology providers/vendors may store User Personal Data in its database located in Singapore. If the User visits the Asa Ren site from a country other than Indonesia, User communication through the Asa Ren site or one of the Asa Ren services may result in the transfer of information across international borders. By using the Asa Ren Platform or one of Asa Ren's services, the User consents to the collection, storage and processing of User information in Singapore.
Retention of User Information
Asa Ren only keeps User's information as long as it is required contractually, operationally, or legally. When Asa Ren no longer needs the information, it will be destroyed or de-identified. During the use of the Platform, the User has the right at any time to ask Asa Ren to end processing, delete and/or destroy User's Personal Data on the Platform and Asa Ren must comply with User's request no later than 7 (seven) working days from request accepted.
Terms of Account Deletion from the Platform
- Deletion of an account and the information and services contained therein is permanent and irreversible. After successful deletion, the User will not be able to log in and view the account history and User Sub-Accounts again. Deletion of a User Account also includes deletion of Sub-Accounts that Users have in User Accounts or vice versa;
- Asa Ren may refuse to delete a User's Account as long as the User still has ongoing orders on the Platform;
- The mechanism for deleting a User Account is as follows:
- Users can delete User accounts by pressing the "Delete Account" button in the Main Account Profile Settings;
- After 30 (thirty) calendar days of User account deletion request, User Account will be permanently deleted, and User can no longer retrieve User information. Prior to 30 (thirty) calendar days the User can still cancel the account deletion by logging in or accessing the User account again on the Platform;
- Users can log in and download a copy of User information from the Platform before deleting a User account. After the User's account is deleted, the User cannot have access using the User's registered e-mail on the Asa Ren Platform.
Asa Ren can delete a User's account if there is a violation of the Terms of Service. Asa Ren will notify the User if there is a suspicion of a violation and/or any report of a violation. The user can clarify regarding this violation within 7 (seven) calendar days from the notification from Asa Ren, in the event that the User fails to clarify at the specified time and/or the User's clarification does not reach Asa Ren's satisfaction, Asa Ren has the right to delete the User's account 30 (thirty) calendar days after notification.
For User accounts that have been deleted for any reason, Asa Ren has the right to store all forms of User Personal Data with reference to the applicable laws and regulations. If desired, the User can ask Asa Ren to delete and/or destroy all forms of User's personal data in the User's account, and Asa Ren must fulfill the User's request no later than 7 (seven) working days. Asa Ren notifies the User of the deletion and/or destruction of Personal Data and provides written evidence that the deletion of data has been carried out at the request of the owner of the Personal Data based on the applicable laws and regulations.
Asa Ren uses reasonable physical, technological, organizational and contractual safeguards, in accordance with the sensitivity of the information, to protect the Personal Data that Asa Ren owns or is under the control of Asa Ren, from unauthorized access, disclosure or use. Asa Ren is committed to its best efforts to carry out appropriate safeguards for User's personal data information to protect User's personal data information. As an implementation of the implementation of security measures, that security measures carried out by Asa Ren are in accordance with the AWS system that can be seen on the page of Amazon Web Service’s Compliance Resource in https://aws.amazon.com/compliance/resources/ page
Access User Information
When requested in writing, Asa Ren will notify the User about the whereabouts, use, and disclosure of the User's Personal Data that Asa Ren stores. Asa Ren may not be able to provide the User with all the information that the User requests, depending on the situation, and there may be a fee for a copy of the User's Personal Data. Asa Ren is required to provide access as intended no later than 3x24 hours after Asa Ren receives a request from the User. However, Asa Ren is obliged to refuse to provide such access to Personal Data if it endangers security, the Health of Users or other parties, impacts the disclosure of Personal Data belonging to other parties, and/or is contrary to the interests of national defense and security as regulated in laws and regulations
Correcting User Information
Asa Ren will make reasonable efforts to keep User information accurate and up to date. If changes or corrections are needed, please inform Asa Ren immediately by email by including details of changes to User information along with supporting evidence. Asa Ren will make the appropriate updates necessary to keep things running smoothly. Asa Ren reserves the right to make corrections to information User's Personal Data if there are changes/corrections to Personal Data including when the User uses services that are connected from third parties. User can review User Personal Data by viewing the correspondence that Asa Ren sends to Users, through an account online Users with Asa Ren, or by requesting access to User Personal Data, as described above. User guarantees that all information provided to Asa Ren is correct. Asa Ren is not responsible for the consequences that arise in the event of an error in the information provided to Asa Ren. The user guarantees the correctness of the Personal Data information submitted to Asa Ren. Asa Ren has the right to request supporting documents proving the validity of User's Personal Data. The User's failure to fulfill the guarantee of correctness of Personal Data information results in Asa Ren having the right to suspend the service and/or account and/or delete the User's account.
How Long Asa Ren Store Information DataUser
Asa Ren retains User information as long as necessary, for example, to comply with a contractual relationship with the User or to provide the User with Asa Ren services. If Asa Ren does not need the User's information to provide services to the User, Asa Ren only stores it as long as Asa Ren has a legitimate business purpose in storing the data, as permitted by applicable law. Asa Ren can store User data for five (5) years (or longer if necessary) for purposes in the event of an Asa Ren legal obligation, or if necessary to file, enforce, or defend legal claims. After the User stops using the Asa Ren Platform and the five (5) year storage period has passed, Asa Ren stores User information in aggregate and anonymous form. Information not identifying Personal Data may be stored for an unlimited period of time for analytical purposes. In addition, Asa Ren does not sell or rent User Personal Data or use User DNA Reports for marketing or advertising purposes without User's consent during and after the above period.
How is Asa Ren Securing User Information?
Asa Ren will provide security to protect and secure all User Personal Data on the Asa Ren Platform in accordance with applicable 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 function and job description. Asa Ren also requires the appointed party to implement and maintain User Personal Data information both administratively, physically and technically.
Please note that the User is also responsible for maintaining the confidentiality of the User's Personal Data, including the User's e-mail, username and password on the Asa Ren Platform. In the event that there is an alleged misuse of a User's account without the User's knowledge and consent, please inform Asa Ren of the allegation. Asa Ren will coordinate and take actions deemed necessary to restore the User's account.
Acceptance of Promotional Ads
Users can choose whether or not to receive any promotional emails from Asa Ren regarding products and/or services by giving approval to Asa Ren. Asa Ren will only send promotional emails based on the User's consent.
Users can refer other parties to Asa Ren by entering their email address. The User guarantees that the party that provides User email to the User has given his consent to communicate with Asa Ren. Thus Asa Ren can send information to them regarding the Asa Ren Platform.
Asa Ren will give its best effort so that the use of the Asa Ren Platform is protected from disturbances such as including but not limited to viruses and malware. Asa Ren will notify the User in writing in the event of an interruption and/or system failure in connection with the processing of the User's personal data no later than 14 (fourteen) days after the interruption and/or failure is known.
Release of Liability
User Personal Data After User Account Deletion
If the User has feedback or question regarding User's concerns about Data Protection, User can contact at firstname.lastname@example.org. Every complaint will be accepted by Asa Ren. After that, the Asa Ren Legal Officer will review and assess the complaint or response with the evaluation results based on the General Data Protection Regulations or applicable laws and regulations.