Galena - Privacy Policy
Privacy Policy
Last updated: February 9, 2025
This Privacy Policy explains how we collect, use, and share your information when you use our Services. It also informs you about your privacy rights and how the law protects you.
We use your personal data to provide and improve our Services. By using our Services, you agree to the collection and use of your information in accordance with this Privacy Policy.
1. Interpretation and Definitions
1) Interpretation
Words with capitalized first letters have specific meanings defined below. These definitions apply whether the terms are used in singular or plural.
2) Definitions
For the purpose of this Privacy Policy:
[Account] means a unique account created for you to access our Services or parts of our Services.
[Affiliate] means an entity that controls, is controlled by, or is under common control with a party, where “control” means owning 50% or more of the shares, equity interest, or other voting rights.
[App] means the software program provided by the Company and downloaded by you onto any electronic device, named Galena.
[Company] (referred to as “the Company”, “we”, “our”, or “us” in this Agreement) refers to PT Kawan Lama Inovasi, Jalan Puri Kencana No. 1. For GDPR purposes, the Company is the Data Controller.
[Country] refers to Indonesia.
[Data Controller] means the Company, which determines the purposes and means of processing your Personal Data, as defined under GDPR.
[Device] means any device that can access our Services, such as a computer, mobile phone, or digital tablet.
[Personal Data] means any information that relates to an identifiable individual. Under GDPR, this includes details like your name, ID number, location data, online identifiers, or factors specific to your identity.
[Services] refers to the App.
[Service Provider] means any person or company that processes data on behalf of the Company. This includes third-party companies hired to help provide or analyze the Services. Under GDPR, Service Providers are considered Data Processors.
[Usage Data] refers to information collected automatically, either generated by your use of the Service or from the Service infrastructure itself (e.g., time spent on a page).
[You] means the individual using our Services, or a company or organization acting on behalf of that individual. Under GDPR, ‘You’ may also be referred to as the Data Subject.
2. Collection and Use of Your Personal Data
1) Types of Data Collected
A. Personal Data
When you use our Services, we may ask you to provide personal details that can be used to contact or identify you, such as:
- Email address
- First and last name
- Usage data
B. Usage Data
We automatically collect Usage Data when you use the Services. This may include your device’s IP address, browser type and version, the pages you visit, time and date of your visit, how long you stay on each page, unique device identifiers, and other diagnostic data.
When accessing the Services through a mobile device, we may also collect information like the type of mobile device, unique device ID, IP address, operating system, browser type, and other diagnostic data.
C. Data Collected Through the App
When you use our App, we may collect the following information with your permission to enable certain features:
● Images and other information from your device’s camera and photo gallery
We use this information to provide features within our Services, as well as to improve and personalize your experience. This information may be uploaded to the Company’s servers and/or Service Provider’s servers, or it may only be stored on your device.
You can enable or disable access to this information at any time through your device settings.
2) How We Use Your Personal Data
The Company may use your Personal Data for the following purposes:
To provide and maintain our Services, including monitoring the use of the Services.
To manage your Account, including registration purposes. The Personal Data you provide allows you to access various features available to registered users.
For contract execution: including the development, fulfillment, and execution of purchase contracts for products, goods, or services you have purchased, or other contracts made through the Services.
To contact you: by email, phone calls, SMS, or other electronic communication methods such as app push notifications, to provide updates or information regarding features, products, or services, including security updates when necessary.
To provide promotional information, including news, special offers, and general information about products, services, or other events similar to those you have purchased or shown interest in, unless you choose not to receive them.
To handle your requests, such as questions, feedback, or complaints you submit to us.
To deliver targeted advertising, we may use your information to display content and ads tailored to your interests and/or location, as well as to measure their effectiveness.
For business purposes: including evaluation or execution of mergers, spin-offs, restructuring, reorganization, dissolution, or sale of assets, including when Personal Data is part of the transferred assets.
For other purposes, such as data analysis, identifying usage trends, evaluating the effectiveness of promotional campaigns, and improving our Services, products, marketing strategies, and your overall experience.
We may share your personal information in the following situations:
With Service Providers: to help us monitor and analyze the use of the Services, display ads on third-party sites, or contact you.
In business transactions, including during negotiations or execution of a merger, company asset sale, financing, or acquisition of all or part of our business by another company.
With Affiliates, your information may be shared with our affiliated companies. Affiliates are required to comply with this Privacy Policy.
With Business Partners: to offer you certain products, services, or promotions.
With other users: when you share personal information in public areas or interact with other users, such information may be viewed by all users and may be publicly distributed.
With your consent, we may share your personal information for other purposes with your consent.
3) Storage of Your Personal Data
We only keep your personal data for as long as necessary for the purposes described in this Privacy Policy, including compliance with legal obligations, resolving disputes, and enforcing agreements.
4) Transfer of Your Data
Your data may be processed in locations outside your country, where privacy laws may differ. By using our Services, you consent to such transfers. We take steps to ensure your data is handled securely and in line with this Privacy Policy.
5) Disclosure of Your Personal Data
A. Business Transactions
If the Company is involved in a merger, acquisition, or sale of assets, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
B. Law Enforcement
In certain circumstances, the Company may be required to disclose your Personal Data if required by law or in response to valid requests by public authorities (e.g., a court or government agency).
C. Other Legal Requirements
The Company may disclose your Personal Data in good faith when such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Services
Protect the personal safety of Service Users or the public
Protect against legal liability
6) Data Security
We take your data security seriously, but no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.
3. Detailed Information on the Processing of Your Personal Data
The Service Providers we use may have access to your Personal Data. These third-party vendors collect, store, use, process, and transfer information about your activities on our Services in accordance with their own Privacy Policies.
1) Email Marketing
We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may choose not to receive some or all of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us.
We may use Email Marketing Service Providers to manage and send emails to you.
[Klaviyo]
Their Privacy Policy can be viewed at: https://www.klaviyo.com/legal/privacy-policy
2) Behavior-Based Remarketing
The Company uses remarketing services to display ads to you after you have accessed or visited our Services. We and our third-party service providers use cookies and non-cookie technologies to help us recognize your Device and understand how you use our Services, so we can improve our Services to match your interests and show ads that are more relevant to you.
These third-party service providers collect, store, use, process, and transfer information about your activity on our Services in accordance with their Privacy Policies, and to allow us to:
Measure and analyze traffic and browsing activities on our Services
Display advertisements for our products and/or services to you on third-party websites or applications
Measure and analyze the performance of our advertising campaigns
Some of these third-party providers may use non-cookie technologies that are not affected by browser settings that block cookies. Your browser may not allow you to block such technologies. You can use the following third-party tools to opt out of the collection and use of your information for interest-based advertising:
NAI opt-out platform: http://www.networkadvertising.org/choices/
EDAA opt-out platform: http://www.youronlinechoices.com/
DAA opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
You can also opt out of receiving all personalized ads by enabling privacy features on your mobile device, such as Limit Ad Tracking (iOS) or Opt Out of Ads Personalization (Android). Please refer to your mobile device’s Help system for more information.
We may share information, such as hashed email addresses (if available) or other online identifiers collected on our Services, with these third-party providers. This allows our third-party providers to recognize you and display ads to you across different devices and browsers. For more details about the technologies used by these third-party providers and their cross-device capabilities, please review the Privacy Policies of each provider listed below.
The third-party vendors we use are:
A. Google Ads (AdWords)
The Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on — https://tools.google.com/dlpage/gaoptout — for your web browser. This add-on allows visitors to prevent their data from being collected and used by Google Analytics.
For more information about Google’s privacy practices, please visit the Google Privacy & Terms page: https://policies.google.com/privacy
B. Facebook
The Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266
To opt out of Facebook’s interest-based ads, follow the instructions provided by Facebook here: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt out of Facebook and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada: http://youradchoices.ca/, or the European Interactive Digital Advertising Alliance in Europe: http://www.youronlinechoices.eu/, or via your mobile device settings.
For more information on Facebook’s privacy practices, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
C. Pinterest
The Pinterest remarketing service is provided by Pinterest Inc.
You can opt out of interest-based ads from Pinterest by enabling the “Do Not Track” feature of your web browser or by following Pinterest’s instructions here: http://help.pinterest.com/en/articles/personalization-and-data
For more information on Pinterest’s privacy practices, please visit their Privacy Policy page: https://about.pinterest.com/en/privacy-policy
3. GDPR Privacy
1) Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
[Consent]: You have given your consent for the processing of Personal Data for one or more specific purposes.
Contract performance: The provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
Legal obligations: The processing of Personal Data is necessary to comply with a legal obligation to which the Company is subject.
Vital interests: The processing of Personal Data is necessary to protect your vital interests or those of another person.
Public interests: The processing of Personal Data is related to a task carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests: The processing of Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly clarify the specific legal basis that applies to the processing, particularly whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
2) Your Rights under GDPR
The Company is committed to respecting the confidentiality of your Personal Data and ensuring that you can exercise your rights.
Under this Privacy Policy, and under applicable law if you are within the European Union, you have the right to:
Request access to your Personal Data. The right to access, update, or delete the information we hold about you. Whenever possible, you can access, update, or request the deletion of your Personal Data directly through your account settings. If you are unable to do this yourself, please contact us for assistance. This also allows you to receive a copy of the Personal Data we hold about you.
Request correction of your Personal Data. You have the right to have any incomplete or inaccurate information we hold about you corrected.
Object to the processing of your Personal Data. This right exists when we rely on legitimate interests as the legal basis for our processing and there is something about your particular situation that makes you want to object to such processing. You also have the right to object when we process your Personal Data for direct marketing purposes.
Request the deletion of your Personal Data. You have the right to ask us to delete or remove your Personal Data when there is no valid reason for us to continue processing it.
Request the transfer of your Personal Data. We will provide your Personal Data to you, or to a third party you have chosen, in a structured, commonly used, and machine-readable format. Please note that this right only applies to automated information that you initially provided consent for us to use, or where we used the information to perform a contract with you.
Withdraw your consent. You have the right to withdraw your consent for the use of your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain features of the Services.
3) Exercising Your Data Protection Rights under GDPR
You may exercise your rights to access, correction, deletion, and objection by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will do our best to respond to you as quickly as possible.
You also have the right to file a complaint with a Data Protection Authority regarding our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
5. Children’s Privacy
Our Services are not directed to anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you become aware that your child has provided us with Personal Data, please contact us. If we learn that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.
If we rely on consent as the legal basis for processing your information, and your country requires parental consent, we may need your parent’s consent before collecting and using that information.
6. Links to Other Websites
Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
7. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will notify you via email and/or a prominent notice on our Services before the change becomes effective, and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
8. Contact Us
If you have any questions about this Privacy Policy, you may contact us:
By email: ahi.care@ahi.id
By visiting this page on our website: https://azko.id/
