PRIVACY POLICY OF UNIVERSITAS BUNDA MULIA

VERSION 1.1-10-2024

INTRODUCTION

Before registering as a recipient of information regarding UBM and/or accessing and/or using Our Services, you are required to read, understand, comply with, and agree to be bound by this Privacy Policy, including any amendments.

Universitas Bunda Mulia, as the owner of the websites ubm.ac.id, sarjana.ubm.id, register.ubm.ac.id, pmb.ubm.ac.id (for Bachelor, Postgraduate, BMLDL), and prospective student portal (in the application form) is committed to protecting your privacy. Hereinafter, Universitas Bunda Mulia will be referred to as “We,” and each will be a data controller (Joint Data Controller) of any Personal Data collected from you.

The term “You” in this Privacy Policy refers to:

1. You who are registered as a recipient of information regarding UBM through registration at ubm.ac.id, sarjana.ubm.id, register.ubm.ac.id, pmb.ubm.ac.id (for Bachelor, Postgraduate, BMLDL), and prospective student portal (in the application form) or through the Whatsapp service; and/or
2. You who are registered as a student of Universitas Bunda Mulia and also recorded as part of the Universitas Bunda Mulia community.

In this Privacy Policy, We explain how We will acquire, collect, process, analyze, store, correct, update, display, announce, transfer, disseminate, disclose, delete, destroy, and/or protect Your Personal Data (“Processing Personal Data”). This Privacy Policy applies to all registrants of information services at ubm.ac.id, register.ubm.ac.id, and sarjana.ubm.id, including when you use the services provided by Us, such as the website services, Universitas Bunda Mulia application, educational program services in the form of any courses offered by Universitas Bunda Mulia, and while pursuing education at Universitas Bunda Mulia (collectively referred to as “Services”).

Please read and understand this Privacy Policy carefully to understand how We implement personal data protection practices.

A. CONSENT TO DATA PROCESSING

By agreeing to this Privacy Policy, you are considered to have: (i) read, understood, and agreed to all provisions in this Privacy Policy, and (ii) granted Us permission to Process Your Personal Data in accordance with this Privacy Policy. In the event that you disclose Personal Data belonging to and/or related to other parties to Us (Personal Data relating to partners, family members, or data subjects other than the provider of Personal Data) for any purpose in connection with the utilization of the Services, We assume that you have obtained consent from the relevant parties as the owners of the Personal Data for the disclosure to Us. Therefore, you represent those other parties in agreeing to the Processing of Personal Data that We have carried out. We may request proof of consent from those other parties at any time, if necessary.

You have the right to withdraw consent for any or all Processing of Your Personal Data; however, you should be aware that We cannot provide optimal Services to you without Processing Your Personal Data, and Your Personal Data Processing is necessary to perform the Services. Furthermore, you hereby acknowledge that by withdrawing consent, you will cause the termination of Services, deletion of your account, or termination of your contractual relationship with Us. However, it is understood that the rights and obligations that have arisen in connection with the contractual relationship between you and Us must still be fulfilled.

We will continue to process Your Personal Data in connection with your request to withdraw consent for a reasonable period from the date the request to withdraw consent is received by Us, and thereafter will not process Your Personal Data unless required by Applicable Laws and Regulations (as defined below).

B. CHANGES TO THE PRIVACY POLICY

We may review and update this Privacy Policy from time to time at Our discretion as necessary. This is done to ensure that the Privacy Policy remains in compliance with developments and changes in applicable legal or regulatory requirements, as well as the Services We provide. If We decide to change this Privacy Policy, We will inform you of those changes through announcements requiring your consent and will publish them in the Privacy Policy section of the Services, requesting your approval. You agree that you have the responsibility to periodically review this Privacy Policy to be informed of the latest information about our data processing and data protection practices, and that by continuing to use Our Services, communicating with Us, or accessing and using the Services after any changes to this Privacy Policy, you will be deemed to have consented to this Privacy Policy and all its amendments.

C. YOUR PERSONAL DATA THAT WE COLLECT AND HOW WE COLLECT IT

“Personal Data” means any data about an identified or identifiable individual, either directly or indirectly, through electronic or non-electronic systems.

In this Privacy Policy, applicable laws and regulations refer to all laws, regulations, provisions, policies, approvals from the government or other state authorities, court decisions, policy guidelines, that are in effect until this Privacy Policy is published and as long as this Privacy Policy remains in effect, including Law No. 27 of 2022 on Personal Data Protection and its implementing regulations (“Applicable Laws and Regulations”).

All Personal Data that We collect depends on the classification of data required according to the basis, purpose, and circumstances of collection in the Personal Data Processing cycle. Additionally, the related Personal Data We collect is based on the needs of the Services or your transaction activity patterns within Our Services.

In accordance with Applicable Laws and Regulations, We obtain, collect, process, analyze, store, correct, update, display, announce, transfer, disseminate, disclose, and/or delete and destroy the Personal Data that We have classified as follows:

1. Individual Data:

1.1. Personal Data that you provide directly when registering as a recipient of information about Universitas Bunda Mulia’s services offline at exhibitions, classes, or other activities conducted by Universitas Bunda Mulia, or through forms on ubm.ac.id, sarjana.ubm.id, register.ubm.ac.id, pmb.ubm.ac.id (for Bachelor, Postgraduate, BMLDL), and prospective student portal (in the application form) or WhatsApp Messenger:

• Name
• Email
• WhatsApp number
• Domicile
• School/university of origin
• Level of education
• Major
• Interested study program
• Employment status
• Company of work (for S2 registration)
• University of origin (for S2 registration)
• Last education data (high school and S1 (for S2 registration))
• Personal data (place and date of birth, religion, gender, citizenship, marital status, Instagram ID, TikTok ID)
• Complete address data (street name, house number, RW/RT, province, sub-district, district, postal code, home phone number, and residence status)
• Complete family data (father/mother’s name, father/mother’s education, father/mother’s job, father/mother’s WA number, number of family members)
• Employment data (father/mother’s company, father/mother’s position, father/mother’s company telephone number, father/mother’s company address, length of service)
• Supporting data (related to the person in charge of tuition fees)
• Birth certificate
• Certificate & National Examination Result Certificate
• Passport
• Visa & ITAS
• Foreign student study permit
• Certificate of graduation
• Certificate of Non-Color Blindness from an eye specialist
• Health certificate
• ID photo 
• Letter of Guarantee for Academic Period and Tuition Fee Payment
• Statement of Unemployment while in Indonesia
• Statement of Non-Participation in Any Political Activities
• Statement of Compliance with Applicable Laws and Regulations in Indonesia

1.2. Your Personal Data that you provide directly when you participate in prize programs and/or become a winner of prize programs for the purpose of winner confirmation, namely:

• Name
• WhatsApp number
• Bank account number
• Tax Identification Number (NPWP)
• ID card (KTP)

2. Technical Data / Your Device including but not limited to IP address, Device Identity (ID), and/or your other updated technical data (if any) and information regarding the manufacturer, model, and version of the operating system of your mobile device. We use your Technical Data to operate the functions of the Universitas Bunda Mulia website and application, resolve technical difficulties, provide you with the correct and updated versions of the website and application, and improve the functionality of the Universitas Bunda Mulia website and application.

Your Google Advertising ID (specific to Android) or Apple Advertising ID (specific to iPhone) will be automatically identified when you download the Universitas Bunda Mulia application for the purpose of processing data related to location, profiling, targeted marketing, and consumer transactions.

3. Log Data including records on servers that receive data such as the device’s IP address, date and time of access, features of the Service or pages viewed, the operation of the Service, and other system activities, browser type, and/or third-party sites or services that the User interacts with before and during interactions with the Service.
4. Location Data. When you use the Universitas Bunda Mulia platform or other services from Universitas Bunda Mulia through your mobile device.

We use this information to process location-related data, profiling, targeted marketing, consumer transactions, and to provide information, including promotional programs, to you.

5. Data Collected Through Cookies and Other Technologies (specific to the Universitas Bunda Mulia website). Information about how you access and use our Website (for example, browser type, access time, and Internet Protocol (IP) address) as well as your hardware and software is automatically collected through the use of cookies (small text files placed on your hard drive) or other technologies and tools. This information is used to enhance the quality of our Website, make our products and services more useful to you, and for other business purposes.
6. Non-Electronic Data. For certain programs, We may also collect non-electronic data that you provide to Us when you use Our Services.
7. Disclaimer. We may:

• create, use, license, or disclose a combination of your Personal Data in the form of statistical or demographic data for any reasonable purpose. Aggregate Data may be derived from your Personal Data but will not be considered Personal Data because this data will not directly or indirectly reveal your identity; and/or
• create, use, license, or disclose available Personal Data,

provided that to carry out the above actions, We will ensure: (i) that elements identifying specific individuals have been removed in such a way that the data, on its own or in conjunction with other available data, cannot be associated with or linked to, or identify anyone; and (ii) that the data is then combined with similar data so that the original data forms part of a larger dataset.

D. PURPOSES OF PERSONAL DATA PROCESSING

We may use the collected Personal Data for the following purposes and for other purposes permitted by Applicable Laws and Regulations (“Purposes”):

• To facilitate the use of the Services or access to Universitas Bunda Mulia;
• To respond to inquiries, feedback, claims, or complaints, either directly or through our customer service agents;
• To provide you with updates regarding the Universitas Bunda Mulia course system, including information about scholarships, study programs, and applicable registration programs;
• To compare information and verify it with third parties to ensure its accuracy;
• To manage and maintain your registered account on our Services, communicate with you, and provide various features, facilities, and functions related to your use of our Services;
• To conduct research on your demographics and transaction behavior;
• To provide insight reports related to your transaction behavior, as well as for research or online interview purposes;
• To provide more targeted information to you as a service recipient (Promote Targeted);
• To conduct Direct Marketing, sending advertising or promotional materials about our Products and Services and/or those of our Business Partners from time to time (unless you choose not to receive such materials);
• To maintain the Service systems and use your data for marketing activities related to products, facilities, promotions, and other services offered by us or by companies within our affiliates, partners, agents, and other third parties designated by us under cooperation agreements (based on your consent as required by Applicable Laws and Regulations); and
• We may also carry out automated decision-making processes in accordance with any or several of the purposes mentioned in section D.1 above.

E. SUBJECTS OF PERSONAL DATA DISCLOSURE

We will share your Personal Data with affiliates, partners, associates, and/or other third parties based on confidentiality agreements as necessary to facilitate the Services for you, to the extent necessary to provide their services, including but not limited to, application development and maintenance, conducting marketing activities, and others.

These third-party services are solely used to process your data for the purposes described in this Privacy Policy. As necessary, we may share your data with government institutions and other relevant authorities based on legitimate orders as required by Applicable Laws and Regulations.

We may also disclose your Personal Data through announcements and/or other public publications to facilitate publications, including but not limited to, marketing, communication, and/or notifications related to winners and/or lotteries.

F. HOW WE DISCLOSE YOUR PERSONAL DATA TO THIRD PARTIES

We may disclose, grant access to, or share your Personal Data with other third parties for the following purposes and for other purposes permitted by Applicable Laws and Regulations:

• To enable service providers and/or goods providers to deliver the Services, process or send orders, including contacting you;
• To respond to inquiries regarding regulations, investigations, decisions, and reporting, to comply with filing requirements as specified in Applicable Laws and Regulations;
• If instructed, requested, or required by the relevant government authorities, for the purposes mentioned in letters, government policies, government regulations, or other Applicable Laws and Regulations;
• For legal purposes, if there are legal proceedings of any kind between you and us or between you and another party related to the Services;
• In connection with any verification processes we or third parties we appoint may require before service providers and/or goods providers offer their services and/or goods to you or your registration as a recipient of information about Universitas Bunda Mulia;
• In the interest of public welfare, we may share your Personal Data with relevant government authorities and/or other authorities designated by the relevant government for purposes of contact tracing, supporting initiatives, policies, or government programs, and other purposes as reasonably required;
• In the event of a merger, asset sale, consolidation or restructuring, financing, or acquisition of all or part of our business by or with another company, for the purposes of such transactions (even if the transaction is not ultimately completed);
• With affiliates or other third parties that assist us in providing the Services, operating our business (including, when you decide to subscribe to our email list, for marketing purposes), for the purposes of assessing and monitoring risks and/or activities that may violate the law (including investigations if necessary), or for the purposes of processing data on our behalf.

When Personal Data is not required to be linked to you, we will make reasonable efforts to remove elements from that Personal Data that can identify you before disclosing or granting access to that data to the relevant third party.

In addition to what is provided in this Privacy Policy, we may disclose and share your Personal Data if we inform you or have obtained your consent for such disclosure or sharing.

G. SCOPE OF PERSONAL DATA PROCESSING

We process your Personal Data both in Indonesia and outside of Indonesia. We may also display, transfer, and disclose your Personal Data to our affiliates and third-party partners outside of Indonesia for the purposes that will be further explained in this Privacy Policy.

H. YOUR RIGHTS FULFILLMENT

You have various rights as a data subject regarding your Personal Data based on Applicable Laws and Regulations.

We respect your rights as a Data Subject granted by Applicable Laws and Regulations, including the right to make corrections to and/or deletions of your Personal Data that is in our possession and control. If you wish to exercise your data subject rights regarding your Personal Data, you can submit a request to us by contacting us at the contact provided in this Privacy Policy. By submitting a request for account deletion, you agree to receive follow-up information that we will send to you through the contact data you provided to us.

We may deny your request for access to, corrections to, and/or deletion of, some or all of your Personal Data that we control if required or necessary under Applicable Laws and Regulations. This includes situations where the Personal Data may contain references to other individuals or where the request for access or the request for correction or deletion is for reasons that we consider irrelevant, trivial, or frivolous or indicated as related to actions that violate the terms of use or involve unlawful activities.

In accordance with Applicable Laws and Regulations, we have the right to charge administrative fees for each access and/or correction request.

I. DURATION OF PERSONAL DATA PROCESSING

We will process your Personal Data as long as you provide and do not withdraw the necessary consent to fulfill the purposes for obtaining and collecting that Personal Data. We will retain your Personal Data while we process it, to fulfill legal obligations, for as long as the Personal Data is within the retention period set by us in accordance with Applicable Laws and Regulations, and/or while the Personal Data relates to the purposes existing at the time the information was collected.

J. HOW WE RETAIN YOUR PERSONAL DATA

Your Personal Data will be retained as long as necessary to fulfill the purposes of its collection, during the retention period, or as long as such retention is required or permitted by Applicable Laws and Regulations. We will cease to retain your Personal Data once it is deemed that the Personal Data is no longer necessary for achieving the purposes of Personal Data Processing, if there is a withdrawal of consent for Personal Data Processing by you, if there is a request from you, and/or if retention is no longer necessary for business purposes or to fulfill legal obligations.

We will delete and/or remove elements that can identify you from the User’s Personal Data under our control if (i) the User’s Personal Data is no longer necessary to fulfill the purposes of its collection; (ii) the retention period ends; and (iii) retention is no longer necessary for compliance purposes according to Applicable Laws and Regulations.

However, it should be noted that there is still a possibility that some of your Personal Data is retained or controlled by other parties, including government institutions, in certain ways. In the event that we share your Personal Data with relevant government institutions and/or other institutions that may be designated by the government or have cooperation with us, you acknowledge and agree that the retention of your Personal Data by the relevant institutions will follow the respective data retention policies of those institutions.

Data communicated between users and service providers conducted outside the use of the Services (such as through phone calls, SMS, mobile messages, or other communication methods and the collection of your Personal Data by our agents) may also be stored in various ways. We do not permit the Processing of Personal Data by service providers that occurs outside our Services. Therefore, you and the service provider are fully responsible for that Personal Data Processing.

To the extent permitted by Applicable Laws and Regulations, you release us from and against any and all claims, losses, liabilities, costs, damages, and expenses (including but not limited to legal fees and full indemnity expenses) arising directly or indirectly from any activities conducted outside our Services.

K. HOW WE PROTECT YOUR PERSONAL DATA CONFIDENTIALITY

We will take reasonable steps to ensure that your Personal Data is kept confidential and secure, and we will take reasonable technical and organizational actions to protect your Personal Data from unlawful or accidental destruction, accidental loss, unlawful or unauthorized processing.

However, you understand and agree that data transmission over the internet is never completely secure, and although we strive to do our best to secure and protect information from unauthorized access, collection, use, or disclosure, and from unlawful processing, accidental loss, destruction, and damage, or similar risks, we cannot guarantee the security of any information provided or sent by you to us. The risk of any provision or transmission of Personal Data by you to us in this manner is solely yours. In the event that your Personal Data is stolen due to malicious software and/or malware and/or viruses originating from your device, we will not be responsible for that risk.

L. WEBSITES AND OTHER SERVICES

The Services and Marketing Materials (as defined below) may contain links to websites or applications operated by third parties, including our affiliates. Any Processing of Personal Data on those websites or applications is entirely controlled by third parties and is the responsibility of the third parties. If you agree to access websites or applications operated by these third parties, you are subject to the terms and conditions and privacy policies of those third-party websites or applications. Therefore, you acknowledge and agree to read the terms and conditions and privacy policies of those third-party websites or applications to understand how they collect and use your Personal Data.

Advertisements on our Services or Marketing Materials serve as links to the advertisers’ websites or applications, and therefore any data they collect based on your clicks on that link will be collected and used by the relevant advertisers in accordance with their privacy policies

M. MARKETING AND PROMOTIONAL ACTIVITIES

We may send you direct marketing, advertisements, and promotional communications through service push notifications, in-service messages, online messenger platforms, Point of Sales, social media, and email (“Marketing Materials”). If you object to receiving Marketing Materials, you can contact us through the contact details provided in this Privacy Policy.

However, please note that we always have the right to send you non-promotional messages that we deem necessary for you at our discretion.

N. CONTACT US

If you have any questions or complaints regarding this Privacy Policy, wish to exercise your rights as a data subject concerning your Personal Data, or require assistance with technical matters, you can contact us at:

Email: [email protected]
CS: 021-690 9090
WhatsApp:+62 811 1056 9090

All correspondence you provide to us will be recorded, documented, and/or stored for the purposes of our company’s archives.

O. GENERAL

1. This Privacy Policy is created based on, interpreted by, and subject to Indonesian law.
2. This Privacy Policy governs the processing of your Personal Data when you access or visit our Site from today onwards until the next revision is uploaded and announced through our Site. You are responsible for periodically checking for any notifications and/or announcements regarding any revisions or changes to this Privacy Policy.
3. The consent you have given in accordance with this Privacy Policy is in addition to and does not replace any other consent you have given to the Company concerning the processing of your Personal Data.
4. To avoid any doubt, if the data protection legislation in Indonesia allows organizations like us to process your Personal Data without your consent, the permission granted by the data protection legislation in Indonesia will always apply.