Q. Privacy Policy For Customers
Privacy Policy for Customer
PRIVACY POLICY
FOR CUSTOMERS 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 visit our website (https://www.uniqlo.com/id/id/) and apps. We only collect and use your personal data as outlined below.
This Policy may only apply to our individual customers. By using our services, 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 using our services, 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
- COOKIES AND RELATED TECHNOLOGIES
- THIRD-PARTY SITES/APPLICATIONS
- 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 “Uniqlo app” is an app called Uniqlo ID, which is created, operated, and managed by the Company as a platform for customers to shop Uniqlo products online with Android and iOS operating systems.
1.8 “you” are data subjects who are:
- Individual customers of the Company, whether active customers, prospective customers, or existing customers who no longer us the Company’s services;
- Employees, officers, representatives, shareholders, directors, contractors, agents, beneficiaries, heirs, or other related individuals of the Company’s legal entity customers or individual customers as mentioned in point (a) above, or a group of people, whether directly or indirectly interacting with the Company, whether as active customers, prospective customers, or existing customers who no longer use the Company’s services;
- Other individuals who interact with the Company other than those mentioned in points (a) and (b) above, such as individuals who visit us through the Uniqlo website, the Uniqlo app, in-store shopping, and individuals who make inquires, reports, or complaints; or
- The individuals mentioned in points (a), (b), and (c) above, who could be a Child, People with Disabilities, or both.
2. PERSONAL DATA WE COLLECT FROM YOU
2.1 The personal data we collect directly from you (for example, when you register as our customer, buy our products, shop in-stores, visit our website, use our app, participate in our promotions, or contact us):
- 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);
- Contact details (e.g., postal code, telephone number, and email address);
- Records of communications between you and us and the personal data you provide to us through those communications (such as communications in the course of making requests, enquiries, reports, or complaints);
- Device information and automatic information from our website and app servers (e.g., browser type, IP address, browsing patterns, the duration of time spent accessing Uniqlo’s website and the Uniqlo app, and the e-newsletter subscriptions on our system);
- Information that you provide when you enter a competition/contest or promotion that we sponsor;
- Information when you report a problem on our website;
- Aggregate information about customer access or visits to the website and information provided by the customer (e.g., when you registered and communicated with us electronically);
- Usage information, which is customer behaviour information that we obtain automatically through the Uniqlo app. We also collect information about how customers use our services, how customers view and interact with our content, the parts of the Uniqlo app the customers use, the information the customers search for, the content that the customers view, correspondences with us, and any actions the customers take on the Uniqlo app;
- Location Information, such as when you download or use the Uniqlo app, we will receive information about your location from your mobile device, including a unique identification contained in your device; and
- Images from cameras in our shops.
2.2 We may combine and/or merge personal data obtained from the Uniqlo app with other data/information obtained by us from other parties in order to provide services to customers.
2.3 Some of your personal data that we collect may include specific personal data (e.g., Child’s data).
2.4 We will only collect Child’s personal data if you, as our customer, provide your Child’s personal data. In any processing we conduct in relation to a Child’s personal data, we assume that you, as a parent or guardian of the Child, have taken the appropriate measures, including reading and understanding this Policy.
2.5 If you do not provide the personal data we require, we may not be able to provide the services you want or fulfil all our obligations to you.
2.6 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:
- Information on the use of our services (e.g., analytics program to monitor your activity on our website and the Uniqlo app, your participation in our events, competitions, contents, and promotions);
- Your communications with us through certain methods (e.g., through social media); and
- Technical information, such as your location when we perform a checking process to confirm your residence and/or when you activate the geolocation function when using our online services, the type of device you use, the operating system and screen resolution, how often you access our services, other characteristics of your device, and other diagnostic data.
3.2 We may collect your personal data from third parties, including our business partners and joint ventures (e.g., third parties collecting an order in your name, third-party payment providers and online advertising partners).
3.3 If you provide the personal data of another person (such as your family) to us, or you ask us to share their personal data with a third party, you hereby confirm that they have been informed and understand the information in this Policy about how we will use their personal data.
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 fulfil necessary matters to conclude an agreement with you;
- To fulfil the Company’s legal obligations in accordance with the provisions of laws and regulations;
- To fulfil legitimate interest of the Company; and/or
- When you have given explicit consent.
We process your personal data for the following purposes:
Purpose of using your personal data |
Communication and Customer Relations
|
Product, Service, and Payment Administration
|
Marketing and Promotional Activities
|
Data Analysis and Market Research
|
Legal, Compliance, and Security
|
Personalisation and User Experience
|
Identity Verification and Security
|
Internal Administrative Purposes
|
Advertising
|
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 |
Our Suppliers |
Business Partners and Joint Ventures |
Our Vendors (including their subcontractors) |
Assignees of Our Rights or Obligations |
Social Media Companies |
Government Bodies |
Law Enforcement Officials and Relevant Authorities |
6. TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF INDONESIA
6.1 We may be required by prevailing laws, regulations, and internal policies to share your personal data to certain third parties to fulfil specific purposes. This may include disclosures to government authorities, law enforcement agencies, or tax authorities in compliance with applicable regulations. In accordance with the PDP Regulations, data sharing may also occur for purposes related to national security, public interest, or law enforcement. Additionally, data may be shared with third parties as part of our operational needs, such as for payment processing, logistics, or other contractual obligations.
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 service providers domiciled outside of Indonesia in order for those service 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, including in the analysis we carry out in relation to our services may involve profiling. This means that we may process your personal data (including specific personal data) using a software that can process your personal data and other factors to predict a risks or outcome. We may also use profiling or other automated methods to make decisions about you related to the e-newsletter on our system to send you personalised greeting, content, information, communication through our various media channels (e.g., mobile app notification, email, chatbot, or any other channel we might develop in future), or location-based services.
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 as long as you maintain an active relationship with us as our customer. Once you no longer actively engage with our services or products, we will retain your personal data based on the specific needs of the business, 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;
- Comply with the relevant laws and regulations, including retaining data for the prevention, detection, and investigation of money laundering and financing of terrorism;
- Defend or take legal actions (such as in a legal dispute);
- Maintain a record of anyone who does not wish to receive marketing offers from us;
- Deal with future complaints about the services we provide;
- Assist in monitoring fraud; or
- Assess the effectiveness of any marketing activities we may have sent you.
8.3 The retention period for personal data is oftentimes linked to the time period to file a lawsuit. We will retain personal data beyond that period if:
- We must do so under an applicable legal obligation; or
- There is a risk of a lawsuit requiring us to retain your personal data.
- 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, or the retention period has elapsed. If you withdraw your consent or request deletion of your data, we will comply with your request in line with the PDP Regulations, except where we are required or authorised to retain the data for legal reasons or business purposes.
- 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 |
Right to access |
Right to rectification, update, and correction |
Right to erasure and deletion |
Right to withdraw consent |
Right to object to an automated decision-making |
Right to restriction |
Right to data portability |
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 services that you can use. 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 18 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 your personal data. We store your personal data by conducting the following:
- Utilising SSL (Secure Sockets Layer) encryption technology to help protect your personal data. By using an SSL-compatible browser such as Microsoft Edge, Google Chrome, 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 is available and protected to areas that store personal data to detect and 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 Unfortunately, the transmission of information via the Internet is not completely secure. You also acknowledge that we cannot guarantee the integrity and accuracy of any personal data you transmit over the internet, nor can we guarantee that such personal data will not be intercepted, accessed, disclosed, altered, or destroyed by unauthorised third parties due to factors beyond our control. We will use all reasonable efforts to protect and secure your personal data against unauthorised access, use, or disclosure, as well as unlawful processing, accidental loss, destruction, or damage. We are not responsible for personal data that you submit to websites or systems masquerading as Uniqlo ID.
10.4 Your password is the key to logging into your account, please use a unique number, letters, and special characters, and do not share your Uniqlo account password with anyone. If you share your password with others, you are responsible for all actions and consequences taken on behalf of your account. If you lose control of your account password, you may lose control of your personal data and other information that you submit to Uniqlo. You may also be subject to legally binding actions taken on your behalf. Therefore, if your password has been unlawfully disclosed or if you have reasonable grounds to believe your password has been unlawfully disclosed, you should contact us immediately and change your account password. You are reminded to always log off from your account and close your browser when you have finished using your shared computer.
10.5 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 18 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, the Uniqlo app, and/or any other appropriate communication channels.
12. COOKIES AND RELATED TECHNOLOGIES
12.1 We use cookies and other online tracking technologies in our online services, such as our website and the Uniqlo app. Please click here for the details of our Cookies and other technologies policy.
13. THIRD-PARTY SITES/APPLICATIONS
13.1 Our services or communications with you (for example via social media) may from time to time contain links to third-party websites, applications, plug-ins or services over which we have no control. Certain activities on our website or the Uniqlo app, such as special promotions, may also be connected to third-party companies that offer you the option to share your personal data with them. We will not share your personal data with these third-party companies; only you can do so if you choose.
13.2 Links to third-party websites provided on our website and the Uniqlo app are offered for your convenience. However, we do not control those websites or their personal data protection practices, which may differ from ours. If you access these third-party links, please note that such third parties have their own personal data protection activities and privacy policies. We recommend you to read such third-party privacy policies to understand your rights.
13.3 Some third-party companies may choose to share their personal data with us, but that sharing is governed by such third party company's privacy policies. We are not responsible for any activities, including data processing activities that occur on systems belonging to third parties.
14. CHANGES TO THIS POLICY
14.1 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.
14.2 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.
14.3 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).
14.4 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.
15. APPLICABILITY
15.1 There may be other provisions concerning personal data which may be made available to you through other documentations other than this Policy.
15.2 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.
16. GOVERNING LAW AND JURISDICTION
16.1 This Policy is regulated and interpreted according to the laws and regulations of the Republic of Indonesia.
16.2 You acknowledge and understand that, except for this Section 16 (Governing Law and Jurisdiction), this Policy does not provide contractual obligations between you and us in relation to this Policy.
16.3 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.
17. NOTIFICATION AND COMMUNICATION
17.1 We may send you messages by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels, including through the Uniqlo app or notifications (messages that appear on your mobile device), as well as through new methods that may become available in future.
17.2 These messages serve the purpose of:
- Helping you manage your Uniqlo app account;
- Fulfilling our legal obligations, such as regarding changes to the agreement with you and notify when there is an incident of failure to protect your personal data;
- Informing you about the features and benefits of the products and services we provide to you; and
- Informing you about products and services (including from other companies) that may be of interest to you. Messages like these are marketing messages. You can ask us to stop or start sending you marketing messages at any time by contacting us.
18. 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.
19. 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.
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