PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CLICKING "REGISTER", "I AGREE TO XPORA'S PRIVACY POLICY", "I AGREE AND APPROVE TO THE COLLECTION, USE, DISCLOSURE, STORAGE, DELIVERY AND/OR PROCESSING OF MY PERSONAL INFORMATION FOR THE PURPOSES SET FORTH IN, AND UNDER THE TERMS OF THE XPORA PRIVACY POLICY" OR SIMILAR STATEMENTS AVAILABLE ON THE XPORA REGISTRATION PAGE OR IN PROVIDING YOU THE SERVICES OR ACCESS TO XPORA, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THE TERMS OF THIS PRIVACY POLICY AND YOU AGREE AND APPROVE TO THE COLLECTION, USE, DISCLOSURE, STORAGE, DELIVERY AND/OR PROCESSING OF YOUR PERSONAL INFORMATION AS DESCRIBED AND BASED ON THE TERMS HEREIN.

We at Xpora ("we") are very concerned with privacy. We believe in transparency, and we are committed to being open about our privacy practices, including how we treat your personal information. By reading this Privacy Policy, you can always make the best decisions about the personal information you share with us. Personal information here refers to any information relating to an identified or identifiable legal subject ("Personal Information"). By registering to and or using Xpora, you acknowledge that you have read this Privacy Policy and Xpora's Terms of Use and understood the content and consequences, and you agree and give consent to us for the collection, use, disclosure and processing of your Personal Information in accordance with this Privacy Policy and or the Terms of Use. Further, you acknowledge that any Personal Information that you provide or will provide is yours to share and is true and accurate.

XPORA is a website aimed at helping prospective entrepreneurs and/or micro, small and medium enterprises (MSMEs). This website is a one-stop solution for users to find their business growing needs.

From time to time, Xpora may revise this Privacy Policy to reflect changes in applicable laws and regulations, our usage practices, our Xpora features and/or technological advances. If we make revisions that change how we use your Personal Information, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy. Therefore, you should review this Privacy Policy periodically so that you are up to date on our latest policies and practices. If you do not agree with the changes or modifications to the Privacy Policy, please do not continue to use your Xpora website. If you continue to use Xpora, then you will be deemed to have agreed to the modification of the Privacy Policy when you use Xpora after the effective date of the modification.

PERSONAL INFORMATION

Personal information means any information about a person and the entities associated with him, whether recorded in written or unwritten form, and whether it is true or not, which can be identified from that data (either directly or indirectly), or from that information and other information.

During the use of the Xpora website and the provision of the Services, we may collect personal information about you, as follows:

1. Information you provide to us
   1. You will be required to provide certain contact information required to register for an Xpora account, including name, e-mail and phone number;
   2. You can provide information about yourself and company identity, including but not limited to complete documents required for the use of the Service;
   3. When using the Check Business Level feature, you can provide the latest information on business conditions, duration of business, type of commodity you trade/interested in, annual turnover, type of business, and your export level.
   4. We will process any information provided to us in connection with a dispute or to support a complaint in connection with Xpora or the services obtained through the Xpora website.
2. Information we collect automatically
   1. We will collect details of User activity, including information related to the results of business level check.
   2. We may be able to collect User data from websites belonging to third parties whose products are displayed on Xpora.
   3. From time to time, we may also collect information about existing and potential Users, during or in connection with business matches or other Xpora-related events.
   4. If you visit the Xpora website, we will automatically collect certain information from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws. Specifically this information may include IP address, device type, unique device identification number, browser type, broad geographic location (e.g. country or city level location), browsing patterns and details about how you interact with our Xpora website and the goods and services available in it. In addition, we collect statistical information about the Xpora website and visitors to the Xpora website including, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Collecting this information allows us to better understand the visitors who come to our Xpora website, where they are coming from, and what content is of interest to them. We use this information for the purposes of our internal analysis and to improve the quality and relevance of our Xpora website. Some of this information may be collected using cookies and similar tracking technologies, as further described under the "COOKIES" section.
3. Information we receive from Partners
   1. Business and business data that you enter when using Xpora and the Partner website;
   2. Information about your device when accessing the application, such as IP Address;
   3. Personal information about you from Partners engaged by us to help provide verification services and comply with our no-money laundering policy and KYC (know-your-customer) checks on Users. This may include your name, email address, company details and contact information.
   4. If you choose to participate in reviewing or rating products and/or services on the Xpora website, we may receive personal information about you from Partners who work with us to review our services and/or rate us.

USE OF PERSONAL INFORMATION

The purposes of the information that can be used by us inside and outside the Republic of Indonesia include:

1. Processing applications;
2. Providing services and information offered via Xpora;
3. Providing services to facilitate trade between the Republic of Indonesia and overseas (or vice versa), and provide contact and business information to those who inquire/request;
4. Our operations, for example, incorporation into our database, analysis, research and auditing;
5. Notifications of Xpora trade shows in the Republic of Indonesia and promotional events or trade shows around the world (and similar events or trade shows organized by our business partners and associates);
6. Distribution of Xpora publications and research materials (and our business partners and associates);
7. Marketing of Xpora services or products (and our business partners and associates engaged in similar or alike activities, such as business matching services, sourcing and conferences);
8. Complying with laws and regulations or codes of ethics within or outside the Republic of Indonesia;
9. Legal proceedings, including collecting overdue amounts against payments;
10. Other objectives directly related to the activities identified above;
11. Crime prevention or detection, and protection of the security and safety of our events and trade shows;
12. Identity verification in any events we organized where it is necessary to verify your identity.

RETENTION

1. We will only retain your personal information for as long as we are required or permitted by law or relevant for the purpose for which it was collected.
2. We will stop storing your personal information, or remove the ways in which data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose of collecting personal data, and is no longer necessary for any legal or business purposes.

COOKIE

We may use cookies and similar technologies (such as web beacons, tags, scripts) to collect information. Cookies are small pieces of information that are stored on your computer or mobile device to help us track your Internet usage. Like like any other website, Xpora, we may use cookies to give you a better experience using Xpora and Xpora will recognize you when you use Xpora in the future. Please disable the cookie option if you want us to stop the cookie feature. Please note that if you do not disable or delete cookies, each time you use the same browser or mobile device to access Xpora, our web servers will be notified of your visit to Xpora and in turn we reserve the right to have knowledge of your visit and your usage patterns. If you disable cookies, you may not be able to access all or part of Xpora, or use all or part of the functionality through Xpora.

Some people choose not to allow cookies, which is why most browsers give you the ability to manage cookies to suit you. You can determine whether and how cookies will be accepted by configuring the privacy settings of the browser you use to access Xpora or your device's "privacy settings". As the way you can refuse cookies through your web browser controls varies from browser to browser, you should visit your browser's help menu for more information. If you adjust the privacy settings in your browser, your device will continue to collect data unless you adjust the device privacy settings, and vice versa.

You have the right to decide whether to accept or reject cookies. If you choose to set your web browser controls to refuse cookies, you may still use Xpora although your access to some Xpora functions and areas may be restricted.

LEGAL BASIS AND DATA PROCESSING

We process personal information for the purposes set out in this Privacy Policy, as described above. Our legal basis for processing personal information will depend on the personal information in question and the specific context in which we collect it. However, we will normally collect and process personal information about you only where it is:

1. necessary to provide services in accordance with the agreement between you and Xpora/or its affiliates (for example, to provide you with the services you have requested and to identify and authenticate you so that you can use Xpora);
2. required to comply with legal requirements (for example, to comply with regulations regarding business matching applications, legality applications, and credit applications);
3. necessary for our legitimate interests and not overridden by your rights.

If we collect and use your personal information in reliance on our legitimate interests (or the interests of any Partner), these interests are typically operating Xpora and our services, managing our relationship with you and communicating with you as necessary to provide our services to you and for our legitimate commercial interests, for example, when responding to your questions, improving our Xpora website and our services, conducting marketing, or for the purpose of ensuring the security of the Xpora website and our services and detecting or preventing illegal activities such as fraud. We reserve the right to have other legitimate interests and if necessary we will explain to you at the relevant time what those legitimate interests are.

If we ask you to provide personal information to comply with legal requirements or to enter into a contract with you, we will explain this at the relevant time. We will notify you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information). In some cases, you may be asked to provide us with personal information to process as described above, so that we can provide you with all of our services, and for you to use all of our Xpora features.

If you have any questions about or require further information regarding the legal basis on which we collect and use your personal information, please contact us using the contact details provided.

YOUR RIGHTS

If you are a resident of Indonesia or outside of the territory of Indonesia, you also have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided under the section below:

1. The right to access, correct, update or request deletion of your personal information.
2. The right to object to the processing of your personal information when it is based on our legitimate interests, and separately the right to object to direct marketing.
3. The right to ask us, in some situations, to limit the processing of your personal information or to request the portability of your personal information.
4. The right to opt-out of marketing communications we send to you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send to you. To opt out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the section.

If we have collected and processed your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we carried out prior to your withdrawal, nor will it affect the processing of your personal information carried out in reliance on a valid processing reason other than consent.

We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws and regulation.

If you become aware of any changes or inaccuracies in your information, you must notify us of those changes so that our records can be updated or corrected.

HOW TO CONTACT US

If you have any requests, questions or concerns about our use of your Personal Data and this Privacy Policy, please contact us at xpora@bni.co.id.

LANGUAGE AND LAW USED

The language used is Indonesian. The law used when there is a dispute is the law applicable in the Republic of Indonesia.