Q. Privacy Policy For Vendors
PRIVACY POLICY
FOR VENDORS AND BUSINESS PARTNER OF PT FAST RETAILING INDONESIA
INTRODUCTION
PT Fast Retailing Indonesia (“Company”, “our”, “us” or “we”) are committed to protecting your privacy and safeguarding your personal data in our possession. This privacy policy will also be known as Personal Data Protection (PDP) Notice (“Policy”) transparently explains how, when, and why we use your personal data, as well as your rights regarding the usage of such personal data when you interact with us. We only collect and use your personal data as outlined below.
This Policy may only apply to our vendors and business partners. By interacting with us, you acknowledge that any personal data you provide to us is true, complete, lawfully obtained, and that you are fully entitled to provide such personal data to us. By interacting with us, you are deemed to have read and understood this Policy.
TABLE OF CONTENTS
- DEFINITION
- PERSONAL DATA WE COLLECT FROM YOU
- YOUR PERSONAL DATA THAT WE COLLECT FROM OTHER SOURCES
- PURPOSES AND LAWFUL BASES WE USE FOR PROCESSING
- SHARING AND/OR DISCLOSURE OF YOUR PERSONAL DATA AND THE RECEIVING PARTIES
- TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF INDONESIA
- AUTOMATED PROCESSING OF YOUR PERSONAL DATA
- PERSONAL DATA STORAGE
- YOUR RIGHTS AS A DATA SUBJECT
- HOW WE PROTECT YOUR PERSONAL DATA
- CORPORATE ACTIONS
- CHANGES TO THIS POLICY
- APPLICABILITY
- GOVERNING LAW AND JURISDICTION
- NOTIFICATION AND COMMUNICATION
- CONTACT US
- LANGUAGE
1.1 “Child” is any individual who is under 18 years old and unmarried.
1.2 “Company” is PT Fast Retailing Indonesia or its successors, where applicable.
1.3 “PDP Regulations” are laws and regulations regarding personal data protection applicable in the Republic of Indonesia, including but not limited to Law No. 27 of 2022 on Personal Data Protection, and other relevant laws and regulations governing personal data protection.
1.4 “People with Disabilities” is every person who experiences physical, intellectual, mental, and/or sensory limitations for a long duration, and who, in interacting with the environment may experience obstacles and difficulties to participate fully and effectively with other citizens based on equal rights.
1.5 “personal data” is data about an identified or identifiable natural person individually or in combination with other information either directly or indirectly through electronic or non-electronic systems. Data where the identity has been removed (anonymised data) is not included in the classification of personal data.
1.6 “processing” or “process” is an event where the Company obtains, collects, uses, displays, announces, discloses, processes, opens access to, stores, transfers, provides, shares, manages, organises, destroys, and/or protects your personal data.
1.7 “you” are data subjects who are vendors and business partners of the Company.
2. PERSONAL DATA WE COLLECT FROM YOU
2.1 Personal data that we collect directly from you, including:
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Identification information (e.g., name, date of birth, address, city, province, product selection, password, bank account and credit-card details and/or any other data required by us with respect to the use of website);
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Contact details (e.g., postal address, phone number, and email address);
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Financial information (e.g., your bank account number);
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Information about the company you are working for (e.g., name of the company and your position in the company); and
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Records of communications between you and us and the personal data you provide to us through those communications (e.g., communications of coordination with the Company, information when you report a problem on our website)
2.3 If you do not provide the personal data we require, we may not be able to process you as a supplier, service provider, and business partner of the Company.
2.4 If you do not provide the personal data we require, we may not be able to process you as a prospective employee of the Company.
2.5 Other than as set out above and if not requested, please do not provide or disclose any of your personal data to us.
3. YOUR PERSONAL DATA THAT WE COLLECT FROM OTHER SOURCES
3.1 We may also collect your personal data from other sources, including:
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Parties within your company who interact directly with the Company (e.g. sales agents of your company, and/or representatives of your company);
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Parties who recommended you to us; and
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Publicly accessible sources (e.g., your company website or social networking platforms).
4. PURPOSES AND LAWFUL BASES WE USE FOR PROCESSING
4.1 We process your personal data with the following lawful bases:
- To fulfil contractual obligations between us and you or to fulfill necessary matters to conclude an agreement with you;
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To fulfil the Company’s legal obligations in accordance with the provisions of laws and regulations;
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To fulfil legitimate interest of the Company;
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To fulfil the protection of your vital interests; and/or
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When you have given explicit consent.
Purpose of using your personal data |
Business Activities
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Legal, Compliance, and Risk Management
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Payments
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Cooperations
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4.2 If we ask for your consent to process your personal data, you may at any time object or withdraw such consent. In relation to your right to object or withdraw consent, please refer to Section 9 of this Policy.
4.3 We may process your personal data for purposes other than those we have listed above. If such processing occurs, we will inform you in advance through updates to this Policy
5. SHARING AND/OR DISCLOSURE OF YOUR PERSONAL DATA AND THE RECEIVING PARTIES
5.1 We will maintain the confidentiality of your personal data, but we may share your personal data with third parties (who must also keep your personal data secure and confidential) in certain circumstances, as follows:
Third Parties Receiving Your Personal Data and the Reasons |
Our Affiliated Companies We are affiliated with several companies, including our parent company (i.e., Fast Retailing Co., Ltd.), Uniqlo’s group of companies, and successors who have the right to conduct our business. We may share certain information with these affiliated companies for purposes such as internal reporting or analysis, including compliance obligations (e.g., adhering to data protection laws, financial reporting requirements, or other regulatory standards) in accordance with applicable laws and regulations in their respective countries. |
Our Suppliers, Service Providers, and Other Business Partners These parties may include, for example, know-your-customer service providers and/or electronic signature service providers. We may also request third-party service providers acting on your behalf to share your personal data with our agents or subcontractors to provide the services you have requested. In the past, we have utilised such services to send letters and emails, reduce repetitive information from customer lists, analyse data, provide marketing assistance, and offer customer service. |
Government Bodies This may include bodies such as Statistics Indonesia, the Ministry of Trade, and the Ministry of Communications and Information Technology, where applicable. |
Third Party Following a Restructuring, Sales or Acquisition We may share your personal data to a third party in the event of a restructuring, sales, or acquisition involving the Company or a debt owed by the Company to such third party, as long as the processing carried out by that third party has the same purpose that you originally informed us of. |
Assignees of Our Rights or Obligations We may share your personal data with anyone who accepts any of our rights or obligations under the terms and conditions of the agreement you have with us. |
Our or Your Advisers This may include accountants, lawyers, notaries and other professional advisers who are authorised to represent us or you, authorised to give instructions, or use products or services on our or your behalf (as stated in the power of attorney). |
Law Enforcement Officials and Relevant Authorities We may share your personal data with law enforcement officials and relevant authorities in Indonesia and overseas in relation to their duties, such as preventing crime (either directly or through third parties) or conducting social or economic statistical research or as maybe required by any other regulatory requirements. |
6. TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF INDONESIA
6.1 We may be required by the laws and regulations to send your personal data to certain parties to fulfil certain purposes..
6.2 Additionally, we may need to transfer your personal data outside of Indonesia, such as for business purposes to our affiliated companies or to suppliers, service providers, and other business partners domiciled outside of Indonesia in order for those other providers to provide their services to us.
6.3 In sending your personal data overseas, please understand that the destination country may have different data protection regulations than Indonesia. In certain circumstances, the court, law enforcement officials, or regulatory bodies in such countries may have the right to access your personal data.
6.4 We will comply with the PDP Regulations and exercise all reasonable and sufficient measures, such as entering into a binding data transfer agreement with data recipients, or obtaining your explicit consent, to ensure that our overseas affiliates, business partners, joint ventures, and all such third parties provide a level of protection comparable to our commitments under this Policy.
6.5 When transferring personal data to organisations in other countries, we will ensure that they agree to apply an equivalent level of personal data protection that we apply. Where this is not possible (for example, if the laws and regulations stipulate that we must transfer personal data), we will ensure that the personal data is transferred in accordance with the applicable laws and regulations. Where a data protection authority does not consider certain countries to have an adequate level of personal data protection, we will establish appropriate safeguards (such as contractual safeguards), in accordance with the PDP Regulations, to ensure that your personal data is adequately protected.
7. AUTOMATED PROCESSING OF YOUR PERSONAL DATA
7.1 Our use of your personal data may involve profiling. This means that we may process your personal data (including specific/sensitive personal data) using software that can process your personal data and other factors to predict risks or outcome. We may also use profiling or other automated methods, to make decisions about you related to the following matters:
- Inspection of anti-money laundering and countering the financing of terrorism;
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Identity and address check; and
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Prevention of criminal offences or fraud.
7.2 The above activity is known as ‘automated decision-making’ and we do this as part of the purposes for which we use your personal data and the lawful bases we have set out in Section 4 of this Policy.
7.3 You may contact us to object automated decision-making on you, as we have set out in Section 9 of this Policy
8. PERSONAL DATA STORAGE
8.1 We will retain your personal data for a specified period of time. After our relationship with you has ended (e.g., after the end of our cooperation agreement), we will only retain your personal data for a period of time appropriate for the type of personal data and the purpose for which it is retained, or for as long as such retention is required or authorised by applicable laws and regulations.
8.2 We will only retain your personal data that enables us to, among others:
- Keep a record of our business activities for analytical or audit purposes;
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Comply with the relevant laws and regulations, including retaining data for the prevention, detection, and investigation of money laundering and financing of terrorism);
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Defend or take legal actions (such as in a legal dispute), including to anticipate such legal actions legal action in relation to our relationship with you or your company; or
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Assist in monitoring the prevention of fraud offences.
8.4 We will delete, destroy, or remove the means by which the personal data can be associated with you as an individual if the personal data is no longer needed for the purposes we have outlined, if the retention period has elapsed, and retention is no longer necessary for legal or business purposes.
8.5 Please note that there is still the possibility that some of your personal data might be retained by the third parties, including by the government institutions in some manner. In the event we share your personal data to the authorised government institutions and/or other institutions that may be appointed by the government authorities or have a cooperation with us, you agree and acknowledge that their data retention policies will apply, and you acknowledge that we have no control over such retention.
9. YOUR RIGHTS AS A DATA SUBJECT
9.1 You have certain rights as a data subject, as set out below:
Your rights |
Right to be informed You have the right to be informed about the Company’s identity and accountability, the purposes of data processing, and the lawful basis for such processing. |
Right to access You have the right to request and obtain access to your personal data that we hold at any time, including obtaining a copy of this data. |
Right to rectification, update, and correction You have the right to complete, update, and correct any errors or inaccuracies in your personal data. |
Right to erasure and deletion You have the right to request the cessation of processing, deletion, or destruction of your personal data. |
Right to withdraw consent You have the right to withdraw your consent for the processing of your personal data at any time. |
Right to object to an automated decision-making You have the right to object to decisions made solely based on automated processing, which has legal consequences or significant impacts on you. |
Right to restriction You have the right to request a delay or limitation in the processing of your personal data proportionally. |
Right to data portability You have the right to request that your personal data be moved or transferred from our system to another system, where it is technically and securely feasible. |
9.2 Your ability to apply for the fulfilment of these rights depends on a number of factors, and in some circumstances, we may not be able to comply to your request. This may include circumstances where the personal data may contain references to other individuals or where the request for access or request to correct is for reasons which we reasonably consider to be trivial, frivolous or vexatious.
9.3 Please note that the exercise of certain rights (such as withdrawal of consent) may affect access to and/or limit the Company’s obligations to you or the company where you work. Additionally, withdrawal of consent may also take at least three (3) days to process.
9.4 In certain circumstances and where reasonable and enforceable under the PDP Regulations, we may charge you a reasonable fee for our administrative costs in the fulfilment of your rights.
9.5 If you want further information about your rights or you want to make a request to exercise your rights, you may contact us in written form through our contact details as set out in Section 16 of this Policy
10. HOW WE PROTECT YOUR PERSONAL DATA
10.1 We take the security of your personal data very seriously and make reasonable efforts to protect any of your personal data. We constantly endeavour to improve our standards of protection, however, we are not liable for any losses arising from the destruction or loss of your personal data that occurs beyond our control. We store your personal data by:
- Utilising SSL (Secure Sockets Later) encryption technology to help protect your personal data. By using an SSL compatible browser such as Microsoft Internet Explorer, Mozilla Firefox, or Safari, you can help ensure that your personal data is inaccessible to unauthorised users and processed confidentially;
- Limiting the access to your personal data;
- Ensuring audit logs are available to areas that store personal data to prevent unauthorised access;
- Securely destroy your personal data when we no longer need it for the purposes outlined in Section 4 of this Policy; and
- Implementing strict internal policies for the safe and appropriate management and storage of personal data, including training staff on data security best practices.
10.2 We constantly endeavour to improve our standards of protection; however, you acknowledge that we are not liable for any losses arising from the destruction or loss of your personal data that occurs beyond our control.
10.3 In the unlikely event that we believe the security of your personal data in our possession or control may have been compromised, we may notify you at our sole discretion no later than the statutory deadline. If notification is appropriate or required by the PDP Regulations, we will endeavour to do so as promptly as possible under the circumstances, but no later than the statutory deadline for notification under the PDP Regulations after becoming aware of the issue. If we have your email address, we may notify you by email. By using this website, you agree to our use of email as a means of such notification.
11. CORPORATE ACTIONS
11.1 There may be circumstances where we transfer some or all of our assets. Such corporate action may have some implications to your personal data. We may take such steps in the case of a merger, spin-off, acquisition, consolidation, or dissolution of our legal entity, sale of assets or other matters in accordance with the relevant laws and regulations. We will ensure that any such sale or transfer is conducted in accordance with the PDP Regulations and that adequate security measures are in place to protect your personal data.
11.2 We may also disclose your personal data to third party involved in the transaction, such as legal consultants, auditors, and regulatory authorities when necessary for the purpose of completing corporate actions.
11.3 You reserve the right to be informed of any changes in the ownership or control of your personal data and the purposes for which it is processed following the above corporate actions. If you have any concerns or questions about how your personal data will be handled in the event of a corporate action involving us, please contact us through our contact details as set out in Section 16 of this Policy.
11.4 In the event of a corporate action involving us, we may update this Policy to reflect any changes in how we process your personal data. Any updates will be communicated to you through our website, Uniqlo app, and/or any other appropriate communication channels.
12.CHANGES TO THIS POLICY
12.1 We may review and amend this Policy from time to time to ensure it remains consistent with our services, future developments, and changes in legal or regulatory requirements. Before these changes are effective, we will notify you of the changes by posting the information of the changes on the website or through your email. We recommend you to review this page from time to time to stay informed with the latest updates on how we enforce the provisions of this Policy.
12.2 You understand and agree that it is your responsibility to regularly review this Policy for updates. You further understand that your continued use of our website, communication with us, or access to and use of our services following any amendments will constitute your acceptance of this Policy and its amendments.
12.3 If the changes to this Policy will have a substantial impact on what we do with your personal data or on you personally, we will provide sufficient notice to enable you to exercise your rights (e.g., to object to the data processing).
12.4 The latest version of this Policy will always be available on our website. We recommend reviewing it every time before engaging with us to ensure you agree with the terms.
13. APPLICABILITY
13.1 There may be other provisions concerning personal data which may be made available to you through other documentations other than this Policy.
13.2 In the event of a conflict between such other provisions and the provisions under this Policy, the provisions under this Policy shall prevail, unless expressly stated otherwise in such other documentation.
14. GOVERNING LAW AND JURISDICTION
14.1 This Policy is regulated and interpreted according to the laws and regulations of the Republic of Indonesia.
14.2 You acknowledge and understand that, except for this Section 14 (Governing Law and Jurisdiction), this Policy does not provide contractual obligations between you and us in relation to this Policy. .
14.3 Any dispute arising out of or in connection with this Policy, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Indonesian National Arbitration Board (Badan Arbitrase Nasional Indonesia or “BANI”) in accordance with the Arbitration Rules of BANI in force at the time, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be Jakarta, Indonesia. The tribunal shall consist of an arbitrator appointed by the Head of BANI. The language of the arbitration shall be Indonesian.
15. NOTIFICATION AND COMMUNICATION
15.1 We may send you messages by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels.
15.2 These messages may be for the purpose of fulfilling our legal obligations, such as notification when there is an incident of failure to protect your personal data.
16. CONTACT US
You may contact us, such as to ask any questions regarding this Policy or to request the fulfilment of your rights as a data subject. You can contact us here.
17. LANGUAGE
This Policy is available in both Indonesian and English. In the event of any inconsistency or different interpretation between the two versions, the English version of this Policy shall prevail.