Privacy Policy

Privacy Policy

The term "JEC Online Services" covers www.jec.co.id (each a "website") and use of the JEC application downloadable from the Apple Store and the Google Play store (collectively, the "JEC").

PT. Nitrasanata Dharma ("JEC Eye Hospitals and Clinics", "we" or "us") have prepared this Privacy Policy for:

•    any individual who uses the JEC JEC Online Services;

•    any individual who interacts with us via our website, email or phone calls ; and

•    any individual who receives promotional communications from us, (collectively, the "users", "individuals" or "you").

This privacy policy explains the types of personal information (or personally identifiable information) we collect and use about you (and in which circumstances we do so) in conjunction with the use of JEC Online Services, who we share this data with, how we protect it, and your rights in relation to this data. We are fully committed to protect your privacy by complying with this privacy policy and any applicable law.

This privacy policy applies to JEC Online Services only and does not cover information collected by any third-party sites to which JEC Online Services links. 

This privacy policy is part of, and must be read in conjunction with, JEC Online Services Terms of Use available inside the app and also at the footer of every website page. 

Notice Prior to Use

We encourage you to read this Privacy Policy before using JEC Online Services or submitting information to us.

Information Voluntarily Provided by Users

You can visit a portion of the JEC Online Services without disclosing your personal information. Some areas of the JEC Online Services allow you to contact us to ask questions or provide comments. When you communicate with us and request a response, we ask for your name and contact information. We use this information so that we can respond more efficiently and keep track of our correspondence. If you do provide information of third parties, please ensure that you do have their consent to do so. When you request an appointment we will ask for personal information which will be used to respond to your request in the most efficient manner. Information you provide to us when booking an appointment, submitting an enquiry or providing feedbacks or comments may include health data, genetic data or other categories of personal information which may be considered sensitive or special under the Indonesia Law. Except as provided at "Transfers of Your Personal Information" below, JEC Online Services will not sell, rent or otherwise disclose your personally identifiable information.

Use and Disclosure of Non-Personally Identifiable Information

JEC Online Services will not treat as confidential any information that you provide that is not personally identifiable. You should be aware that JEC Online Services will be free to disclose through any means and use for any purpose such non-personally identifiable information in its sole discretion. By providing such information to JEC Online Services, you understand and agree that no relationship has been created between JEC Online Services and you, and JEC Online Services have no obligation to you whatsoever regarding that information, unless otherwise required by applicable law.

Use of Cookies

JEC Online Services use cookies for a variety of purposes, including remembering your user name if you register or login, remembering some of your customized user preferences, help us better understand how people use our Online Services. To disable or limit the use of cookies, please refer to the options settings inside your Internet Browser. If you do so, however, some pages on this JEC Online Services may not work correctly.

Web Server Logging and IP Addresses

JEC Online Services retain usage data, such as the source IP address that a page request is coming from, your IP address, domain name, date and time of the request, the referring JEC Online Services, and other parameters passed on the URL. We use this data to better understand JEC Online Services usage. This information is stored in log files and is used by JEC Online Services for statistical reporting, IT security and to improve our website functionalities and your user experience.

Purposes and legal bases for using personal information

Where the legal basis for using your personal information is our legitimate interest (as identified above for specific purposes of use of information), we believe that our legitimate interest overrides your privacy rights (also considering the adequate security measures we implement to protect your personal information).

Transfers of your personal information

We may need to disclose your personal information to the following categories of third parties for the purposes described above (under "Purposes and legal bases for using personal information"):

Other group companies

As JEC Eye Hospitals and Clinics is part of a wider group with headquarters in Indonesia which all collaborate and partially share customer services and systems including website-related services and systems, we may need to transfer your personal information to, or otherwise allow access to such data by other companies within the our group for the purposes set out above including, for example, addressing your queries, providing you with our website services from any locations you request them, ensuring the security of our website and your personal information, informing you about our services and promotions.

Our service providers

We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. We may share personal information with the following categories of Service Provider:

• infrastructure and IT services providers;

• marketing, advertising and communications agencies;

• JEC Eye Hospitals and Clinics Doctors

• JEC Eye Hospitals and Clinics Referral Offices

• Insurance Companies

In the course of providing such services, these Service Providers may have access to your personal information. However, we will only provide our Service Providers with the information that is necessary for them to perform the services, and we ask them not to use your information for any other purpose. We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal information secure.

Third parties permitted by law

In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, or to judicial or administrative authorities).

We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our contractual terms or protect your rights or those of the public.

Third parties connected with corporate transactions

We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Policy.

International transfers of your personal information

The personal information that we collect from you may be transferred to, and stored by us in Indonesia or other destination outside Indonesia, including within our group of companies or through the use of third parties as set out under the section "Transfers of your personal information" above. 

We will take all necessary measures to ensure that your personal information is securely transferred, stored and used after transfer, as required by applicable law, you can ask for a copy of such appropriate safeguards by contacting us as set out below ("Questions").

Access, Update, Correction of Personally Identifiable Information and other rights of the individuals

You may contact us at jec@jec.co.id to access, update or correct your personally identifiable information that you provide to us through the JEC Online Services.

If your personal information is subject to EU data protection law, you have a number of rights with respect to such information. These can be summarized as follows:

  • Access. You have the right to request a copy of the personal information we are processing about you, which we will provide back to you in electronic form. For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information. If you require multiple copies of your personal information, we may charge a reasonable administration fee.
  • Rectification. You have the right to have incomplete or inaccurate personal information that we process about you rectified.
  • Deletion. You have the right to request that we delete personal information that we process about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
  • Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
  • Portability. You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent (such as for direct marketing communications) or to perform a contract with you (such as to administer your account).     
  • Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
  • Withdrawing Consent.  If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge.  This includes cases where you wish to opt out from marketing messages that you receive from us.

To exercise any of your rights above, please contact us as stated under below ("Questions").

You also have the right to lodge a complaint with the local data protection authority in the INDONESIA if you believe that we have not complied with applicable data protection laws.

Period of retention of your personal information 

Your personal information is stored by us and/or our Service Providers on our behalf, strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the information is collected. When personal information is kept, that period will be determined based on the applicable local law. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

Security

We take advanced technical and organizational safeguards to protect personally identifiable information collected through JEC Online Services and used in accordance with this Privacy Policy. In addition to technical safeguards, we also use physical controls and procedures to secure your personally identifiable information. However, we cannot guarantee that it is completely secure from people who might attempt to evade our security measures or intercept transmissions over the Internet.

Changes in Our Privacy Policy

JEC Eye Hospitals and Clinics may at any time modify this privacy policy.  

Questions

If you have any questions about this Privacy Policy or you want to exercise any of your rights under the applicable law, please contact us via jec@jec.co.id.

 

01-June-2019

 

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