PT Suar Inspirasi Produktif (hereinafter referred to as "SUAR") is committed to maintaining and protecting the personal data of all users, customers, partners, service providers, and other parties who interact with the services and/or platforms provided by SUAR.

In the formulation and implementation of this policy, SUAR considers aspects of technology implementation, internal governance and human resource capabilities to ensure that personal data management is carried out in a secure, transparent and accountable manner.

Therefore, in this Personal Data Protection Policy, SUAR expressly takes into account various important aspects that include the use and development of information technology, the competence and integrity of the human resources involved, and the operational procedures implemented internally. The entire process is structured and executed with reference to the legal and regulatory framework applicable in the territory of the Republic of Indonesia, including government provisions, implementing regulations, and policy standards relevant in the context of personal data protection.

This Policy applies as a binding basis for all parties using SUAR services, and becomes an integral part of the legal relationship between users and SUAR.

A. Definition

SUAR are PT Suar Inspirasi Produktif, a business entity engaged in digital media, content development, and other related services.

Affiliate is any entity, legal entity or other company that is directly or indirectly under the ownership, control or strategic cooperation with SUAR.

Services refer to any products, services, activities or other forms of services provided, managed and/or organized by SUAR, whether through digital media (including but not limited to websites and applications) or offline, such as public activities, training or other forms of interaction.

Portal means any website, software application, digital platform and/or other electronic system provided or operated by SUAR, whether currently available or developed in the future to support the provision of the Services.

Customer/User/You/Self is any individual or legal entity that accesses, uses, or interacts with SUAR Services, either through the Portal or directly, and is registered or not registered with the SUAR system.

Personal Data/data is any information that can directly or indirectly be used to identify you as an individual, obtained by SUAR through interaction or use of the Services, including but not limited to your name, address, place and date of birth, telephone number, email address, occupation, identity documents, and/or other information associated with your personal identity.

Terms of Use refer to the terms, policies and/or guidelines set by SUAR relating to the use of the Portal and/or Services, which may be updated and changed at any time in accordance with SUAR's policies.

B. Scope

This Personal Data Protection Policy applies to all Personal Data collected, stored, processed, and/or used within the scope of all Services provided by SUAR, including but not limited to digital services, offline interactions, and services organized with business partners, vendors, service providers, and other stakeholders working with SUAR.

Any future addition of new products, services, features, platforms or business units developed, operated or officially recognized by SUAR will automatically be subject to and become an integral part of this Personal Data Protection Policy.

In the event that it is necessary to prove the management of a product or service as part of SUAR, the Company reserves the right to provide a legally valid written statement as a form of validation, without having to disclose the company's legal documents directly.

C. Purpose

SUAR collects, manages, uses and in certain circumstances may share your Personal Data with relevant third parties or partners, for the following purposes:

1. Provide service-related support or information:
   Your Personal Data may be used to provide assistance, clarification or response to previous interactions with SUAR's services, including but not limited to complaint handling, customer service follow-up and service confirmation conducted in person or through digital platforms.
2. Delivering information regarding product and service updates:
   SUAR may use your Personal Data to provide information regarding product launches, service developments, promotions, personalized offers, event invitations and other forms of communication deemed relevant. This includes information about the services you have or have not used, both from SUAR and from business partners who legitimately cooperate with SUAR.
3. Analyzing user behavior to improve service experience:
   Your Personal Data and interaction records may be used to understand your preferences, usage patterns and interests so that SUAR can provide you with experiences, content and communications that are more relevant, personalized and tailored to your needs.
4. Communicate available benefits, programs or opportunities:
   SUAR may inform you of relevant programs, incentives, special benefits or opportunities available in the context of the services provided.
5. Interacting with third parties or business partners:
   SUAR may share your Personal Data with business partners or third parties involved in the provision of services, execution of transactions or product development in line with SUAR's business interests and operational needs. These parties will be carefully selected and are required to maintain the confidentiality and security of Personal Data in accordance with applicable protection standards.
6. Protecting content and services from misuse:
   SUAR reserves the right to use your Personal Data to detect, prevent and mitigate potential violations of the law and/or misuse of the services, including but not limited to spam, plagiarism, piracy and other unauthorized activities contrary to the Terms of Use.
7. Collecting user suggestions and feedback:
   SUAR may contact you for the purpose of collecting opinions, preferences or feedback to improve the quality of products and services, including through surveys, user research or focus groups.

All activities described in this letter C may be carried out by SUAR within the scope of global operations, while upholding the principles of data protection and user privacy.

D. Data We Collect

SUAR collects Personal Data that you directly provide or that is obtained automatically through your use of the services or your interaction with SUAR's digital systems and platforms.

Personal Data that you directly submit to SUAR includes:

a. Full name
b. Contact information (phone number, email address)
c. Date of birth
d. Place of birth
e. Demographic information such as gender and occupation
f. Legal identity information (ID card, driver's license, passport, or other identification document)
g. Emergency contact information h. Emergency contact information. Emergency contact information
h. Social media profile data
i. Information regarding educational background and employment history
j. Personal preferences and interests
k. Any other information that you upload or voluntarily provide to SUAR in any form.

In addition, SUAR also collects technical and user behavior information when you access the service, which includes:

a. Information about the device used (device type, operating system, settings, and device identification)
b. Service usage information (activity, access time, pages visited, and user interaction)
c. Cookies files
d. User authentication data
e. General location information
f. Additional information recorded automatically during use of the service for the purpose of developing and improving user experience.

About the Use of Cookies

Cookies are small data files in text format that are sent to and stored on your device when you access SUAR services through digital platforms. Cookies allow our systems to recognize your device and customize your experience of using our services.

Cookies are used to remember preferences, improve service performance and serve more relevant content to users. SUAR does not use cookies to directlystore sensitive personal data such as passwords or financial information, nor does it retrieve personal information from your device without consent.

We also use analytics cookies to understand service usage patterns, including frequently accessed pages or most used features, with the aim of improving platform performance and quality. This information is collected and analyzed in an aggregated and anonymous format, and is only shared with our partners for the purpose of evaluating system performance, without revealing the user's identity.

Setting Cookies by User

Most browsers on your computer, smartphone or other device are set to accept cookies by default. However, you have the right to reset or disable the use of cookies through your browser settings. Please refer to the documentation of the browser you are using to customize your cookie preferences according to your needs.

Please note that disabling certain cookies may impact the functionality and performance of some features on the SUAR platform.

E. Data We Do Not Collect

As part of Our commitment to the protection of privacy and data confidentiality, We expressly state that We do not collect certain types of data that are personal and sensitive, including but not limited to photo gallery content, communication content in instant messaging applications, and phonebook data stored on your device.

This step is a form of commitment to upholding individual privacy boundaries and ensuring that data management is only carried out on information that is relevant and necessary in the provision of services.

F. Security

The protection of the confidentiality and integrity of your Personal Data is a top priority for SUAR. We implement reasonable technical and organizational measures in accordance with industry best practices to keep Personal Data secure from the risk of unauthorized access, disclosure, alteration or destruction. Periodic evaluations of security systems are also conducted internally to ensure that data protection policies and procedures remain relevant and effective.

Personal Data stored or transmitted through Our systems is encrypted to mitigate the risk of leakage and misuse. Nevertheless, SUAR cannot guarantee that the system is fully immune from intrusions such as viruses, malware or cyber-attacks by unauthorized parties.

The User has full responsibility for maintaining the confidentiality of the information owned, including access credentials such as account passwords and the security of the device used to access Our services. Users are encouraged not to share personal or authentication information with other parties in any form.

Any risk, loss or abuse arising from user negligence in maintaining the confidentiality or security of account access is not Our responsibility. You hereby release SUAR and its management, employees and other related parties from any demands, claims or compensation that may arise from unauthorized access to Your account or Personal Data through Our services.

G. Provisions for Minors

The creation of an account on the Portal and/or registration to the Services may not be done directly by individuals under the age of 18 (eighteen) years, or under the minimum age limit set by applicable legal provisions. In such cases, the process must be carried out through the representation of a parent or legal guardian.

For Services that are explicitly directed to minor users, all account creation, registration, and use of such Services must still be carried out with the knowledge, supervision, and consent of a parent or legal guardian.

If it is known that a minor has provided Personal Data without a legal representative, the relevant parent or guardian must immediately contact Us (see Section N) to request the deletion of irrelevant Personal Data and ensure the termination of the use of the relevant account and Service-especially if the Service is not intended for the segmentation of minors.

We do not have the ability to directly identify the age of the user during the account creation process or the use of the Services through the Portal. Therefore, all legal consequences for non-compliance with the use as stipulated in this section are entirely the responsibility of the user concerned. Users hereby release Us, affiliates, and related partners from any demands, claims, or lawsuits arising as a result of violations of this provision.

H. Technical and Regulatory Information

1. Users' Personal Information
We obtain and process Users' Personal Data through various interactions, including but not limited to: visits to the Portal, use of features, access to content, account registration, and utilization of available services. The information requested may include, but is not limited to, e-mail addresses, residential or office addresses, telephone numbers, and other relevant data as required by the service.

2. Non-Personal Information of Users
We may also collect information that does not fall under the category of Personal Data, as a result of the User's interaction with Our Portal and/or Services. This information may include browser name, device type, operating system, type of internet service used, and other technical data relating to the User's connection to Our system.

3. Third Party Service Integration
If the User actively links social media accounts or other accounts from third party services to Our Portal and/or Services, then the User gives consent to the third party to send certain data to Us. The data received will be processed, stored, and used in accordance with the provisions of this Policy.

4. Logging and Device Identification Practices
For the purposes of technical analysis and improving user experience, We automatically log IP addresses (for web-based applications) and user sessions (for mobile applications). The technical data logged includes:

• Browser/device type and version
• Operating system
• Date and time of request to the server
• Geographic location (latitude and longitude)

For mobile apps, additional data may include:

• Device brand and/or version
• IMEI number of the device
• Information from the operating system or browser
• Other technical parameters provided by the device

This information is used in an integrated manner across the Services to enable a better understanding of user behavior between products, which in turn supports the improvement of Our overall service quality.

5. External Link Behavior
Some parts of Our Services and Portal may direct Users to sites or applications managed by third parties. We are not responsible for the privacy policies, data collection practices, or content on these sites/applications, even though they contain Our logo or identity elements on them. Users are advised to read the privacy policy of the site/application concerned before continuing the interaction.

6. Response to "Do Not Track" (DNT) Signals
We do not support or respond to DNT signals that may be sent through Users' browser settings, in connection with online behavior-based advertising preferences.

7. Retention of Personal Data
If the User is no longer registered or no longer uses Our Services, the Personal Data that has been collected will still be stored for a minimum of 5 (five) years from the last date of user activity or for another period required under applicable legal provisions.

8. Requests from Authorized Authorities
We reserve the right to share Personal Data with government agencies, law enforcement officials, or other authorized parties in accordance with applicable legal provisions, if necessary as a form of fulfilling legal obligations or in the context of law enforcement processes.

I. Personal Data Statement and Consent

1. By accessing and/or using Our Portal and/or Services, You represent that You have read, understood, and agreed to the entire contents of this Personal Data Policy, including any changes that may be made from time to time. You give consent to Us to collect, use, store, process, and/or transfer Your Personal Data as described in this Policy.
2. Furthermore, You also give approval and authority to Us to share Your Personal Data, including but not limited to the information that You have provided to Us, to Affiliated entities and/or third parties who cooperate with Us (including but not limited to partners, service providers, and vendors), in order to support the operation of Our Services and/or Portal as well as Our and/or Our Affiliates' business activities, as long as it is carried out in accordance with the provisions of the applicable laws and regulations.

J. Revocation of Consent and Erasure of Personal Data

As a registered User, you have the right to review, update, correct or delete your Personal Data stored in your account through the profile settings feature on the SUAR Portal or Application.

SUAR is only responsible for the management and deletion of Personal Data stored in SUAR's systems. We are not responsible for data managed or stored by third parties outside the SUAR system.

You may revoke your consent to the collection, use and disclosure of your Personal Data and submit an account and data deletion request through the following steps:

• For website users, please login and access the user profile menu.
• For app users, make sure you are logged in and access the account settings page.
• If you are unable to access your account, please submit a deletion request by sending an email to: osuaruar.id.

By deleting your SUAR account, you will:

• Delete all of your Personal Data (including personally identifiable data/PII).
• Lost access to make data changes, comments, and other activities that require a login.
• Have no claim rights to prizes, incentives, or benefits from previously participated activities.
• Disconnected from all access to services within the SUAR ecosystem, including but not limited to:
  • Access community platforms, including interactive features or user content.
  • Access to premium content or digital subscriptions (if applicable).
  • Access transaction and purchase history on connected e-commerce services.
• No longer receive marketing emails, product offers or promotional notifications from SUAR.

K. Email Address Policy

If you no longer wish to receive newsletters or other communications, you mayunsubscribe by following theunsubscribe link provided at the bottom of each email sent by our system.

SUAR may send you emails with survey invitations, user feedback, and information about services in development or available.

If you communicate with SUAR by email, the content of that email, including your email address, personal information provided and communication history may be retained by us as part of our communication archive and for service improvement purposes.

We urge you not to send confidential information via email, as communication via electronic mail is not always encrypted or secure. You hereby understand that SUAR shall not be liable for any loss that may result from sending sensitive information via email and shall have no obligation to provide a remedy for any such impact.

L. Dispute Resolution and Language

SUAR and User agree to settle any disputes arising from this Personal Data Policy first through deliberation of consensus within a maximum period of 30 (thirty) working days from the receipt of written notice from one party to the other.

If the deliberative settlement does not result in an agreement, then the dispute will be resolved in accordance with the regulations and legal mechanisms applicable in the jurisdiction of the Republic of Indonesia.

Language: This Personal Data Policy may be provided in multiple language versions. However, in the event of any difference in interpretation or inconsistency between the Bahasa Indonesia version and any other language version, the Bahasa Indonesia version shall be deemed valid and applicable.

M. Changes to Personal Data Policy

SUAR may make changes to this Personal Data Policy from time to time by publishing the latest version on any of its Portals. You hereby acknowledge and agree that SUAR reserves the right to update this Personal Data Policy unilaterally, so you are encouraged to periodically review, read and understand each provision listed.

By continuing to access and/or use the services of SUAR after changes have been made, you are deemed to have read, understood and agreed to this Personal Data Policy and all changes.

If any provision of this Personal Data Policy is declared invalid or unenforceable, the remaining provisions shall remain in full force and effect.

N. Contact Us

If you have any questions, requests or concerns regarding this Personal Data Policy or SUAR's data management practices, please contact us at:

Address: Jl. Dempo I No.32, RT.4/RW.3, Gunung, Kebayoran Baru, South Jakarta, DKI Jakarta 12120
Email: suar

O. Effective Date and Miscellaneous

This Personal Data Policy was last updated on July 27, 2025.

By using the SUAR Portal and/or Services, you acknowledge that you have read, understood and agreed to all the provisions of this Personal Data Policy, including any changes made from time to time.

This Policy shall be subject to and construed in accordance with the provisions of the laws and regulations applicable in the Republic of Indonesia.