Ilmu Pena - Privacy Policy

Last updated: December 1, 2023

Ilmu Pena (“Pena”, “we”, “us” or “our”) is committed to protecting your privacy and ensuring you have a positive experience when you use our product and services (the “Services”). If you do not meet the foregoing condition, you may not register and use our Platform and may use Pena Services only with the involvement of parents or guardians. Capitalized terms that are not defined in this policy have the meaning given to them in the User Agreement： Terms and Condition

Personal Data We Collect & How We Use It

Types of Personal Data	How We Get It	How we use it	Legal Basis
Data you provide For certain activities, such as when you register, upload content to the Platform, or contact us directly, you may provide some or all of the following information:
• Your registration and profile information, such as date of birth, gender, name, phone number, user ID and password, constellation, profile picture (optional), language preference(optional), hobby and status, region and your instruction.	From your provision, disclosure or your prior approval	Enroll you in the Services Display your profile image and information to other users. Send you notifications of one or more types (such as message alerts, identity verification, security verification, etc.) using the contact information (such as phone numbers) you provide while using our products and/or services. Additionally, we may also provide you with commercial information such as services, features, or activities that may interest you through SMS or phone.	Contract Consent
• User-generated content(UGC)，including audios, texts, messages, images, codes and other materials you upload, distribute or stream on the App when you use Pena Services.	From your provision, disclosure or your prior approval	Enable you to share user content and interact with other users Use this information to detect whether content shared contains pornography or other content that violates local laws, community rules or the User Agreement and remove or block content in such cases	Contract Consent Legitimate Interests
• Information through surveys, challenges and competitions in which you participate. Your opt-in choices and correspondence with us, such as information used to verify with your account or to resolve your feedback or complaints.	From your provision, disclosure or your prior approval	Enable you to share user content and interact with other users Run opt-in contests, sweepstakes or other virtual activities Verify your identity and resolve your feedbacks or complaints.	Contract Consent
• Transaction information. Information where required for payment or withdrawal, such as bank account information, or information where necessary in the event for investigation or security, or other third payment information, account name and identity card (where necessary in the event for investigation or security), transaction record and visual item information. The foregoing information is your sensitive information, we will not collect without your prior approval or your self-disclosure, except otherwise such non-approval is allowed by some applicable laws and regulations.	From your provision, disclosure or your prior approval	We use this information to facilitate your payment and maintain a record of your transaction history. We use this information in order to detect fraud on our Services. We access, preserve and share your Personal Information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to comply with any applicable law, regulation, legal process, or governmental request, e.g., anti-laundering investigation from governments	Contract Consent Legal compliance
Operation Data Technical information from Pena’s software or systems hosting the Services, and from the systems, applications and devices that are used to access the Services, such as:
• Usage Information: Usage Information may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, and other diagnostic data.	through your use of the Services Automatically	Facilitate the optimization of the Services Monitor performance of our data centers and networks Provide support Maintain the security of our infrastructure and Services Suggest choices such as language preferences Detect, investigate and stop fraudulent, harmful, unauthorized or illegal activity (“fraud and abuse detection”) Monitor the success of our advertising and marketing programs.	Contract Legitimate interests Legal compliance
• Approximate location (e.g., nearest city or town)	through your use of the Services Automatically	Connect you to the nearest data center Comply with privacy and other laws – for example, so we can provide you with the right notices for your area Suggest choices such as language preferences Monitor performance of our data centers and networks	Contract Legal obligation
• *Device Information:* including device attributes such as operating system, hardware and software versions, model of your device, signal strength, available storage space; device signals, such as Bluetooth signal, nearby Wi-Fi access point; device settings, such as camera; network and connection, such as your mobile carrier, IP address, time zone setting, connection speed, location (e.g. GPS) and identifier, such as unique device identifiers, device IDs, and Identifier for Advertisers (IDFA). You may be able to refuse our collection of IDFA by adjusting your settings of your device. Because each device is different, please consult the instructions provided by your device.	through your use of the Services Automatically	Facilitate the optimization of the Services Monitor performance of our data centers and networks Provide support Maintain the security of our infrastructure and Services Suggest choices such as language preferences Detect, investigate and stop fraudulent, harmful, unauthorized or illegal activity (“fraud and abuse detection”) Monitor the success of our advertising and marketing programs.	Contract Legitimate interests Legal compliance
Information from third parties
Business partner, for example, we work with companies to distribute our apps, provide our infrastructure, delivery, and other systems, process payments, help us understand how people use our Services, and market the Services. Third-Party Social Media Services, third-party social media service's account, such as Your name, Your activities associated with that account.	From third parties	Improve the Platform such as assisting us with content measurement and following your activity on our Platform across your device Help us operate, provide, improve, understand, customize, support, and market the Services.	Contract Consent
Cookies
Cookies and similar technologies (e.g. pixels and ad tags) (collectively, “cookies”) are small files which, when placed on your device, enable us to collect certain information, including personal data, from you in order to provide certain features and functionality.	Some depend on how you configure your cookie settings, others automatically collected	Verify log-in information Monitor the performance of the Service to continually improve it Customize and enhance your online experience	Contract Consent Legitimate Interests

How We Share Personal Data

We are not in the business of selling your information. We consider this information to be a vital part of our relationship with you. However, there are certain circumstances in which we may share your personal data with certain third parties, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, bankruptcy, dissolution or similar event, your information may be part of the transferred assets.
Consent: We may share your information with your consent.
Affiliates: We may also share your information with our affiliates for purposes consistent with this Privacy Policy.
Third Parties: Where we use a third-party service to: (a) process payments; (b) provide customer support (including the provision of a support database and ticketing); (c) send SMS service notification; or (d) provide other services, support, features or functionality as part of the Services
Developers: Developers using our SDK or API will have access to their end users’ information, including message content, message metadata, and voice metadata. Developers must use such information only to provide the SDK/API functionality within their applications and/or services. Legal Requirements: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or our property, (iii) protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

Data Retention

We retain information for as long as necessary to provide our Services and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing our Services, and enhancing the safety, security and stability of our Services), and for the exercise or defence of legal claims.

How We Transfer Your Information

Your information may be processed on servers located outside of the country where you live. We are committed to using and storing information in compliance with applicable privacy laws and to implementing appropriate security measures to protect your information.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

If you have any questions related to data transferred, please contact us via dinur.developer@gmail.com.

Your Rights

You have the right to exercise certain privacy rights available to you under applicable laws. We will process your request in accordance with applicable data protection laws.

Object or restrict the use of data and withdraw consent. You may have the right to request that Pena stop or restrict using or processing your personal data, and you can withdraw your consent.
Access and/or portability. You can access and ask for a copy of the personal data that you provided in some limited circumstances and permitted by applicable laws, you can provide or “port” that data to another provider.
Erasure. In certain circumstances, you may have the right to the erasure of personal data that you provided (for example if it is no longer necessary for the purposes for which it was originally collected).
Rectification. You may have the right to require us to correct any inaccurate or incomplete personal information.
Restriction. You may have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
Deleting your account. If you ask us for deleting your account, we will delete contents you have posted and you created, and then you won’t be able to recover that information later. Information that others have shared about you isn’t part of your account and won’t be deleted. We use reasonable efforts to delete your personal data as required but retain records necessary to comply with a governmental authority or local law.

How to Exercise Your Rights

To exercise any of the rights above, you can email us at dinur.developer@gmail.com.You may also submit a request to the following address:

Ilmu Pena

Jl. Al-Hidayah, No. 46, Kembangan Utara, Kembangan, Jakarta Barat, 11610 Please identify yourself and specify your request. If you have a password protecting Pena account, we will use your account information to verify your identity. If not, we will ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.

Security

Security of your information is important to us. We maintain appropriate technical, administrative, or physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.

Changes to Privacy Policy

We may modify our Privacy Policy from time to time for various reasons including to improve our privacy practices, to reflect changes to our Services, and to comply with relevant laws. We will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Services or providing us with information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.