Zafyre (the “Company”) is committed to maintaining robust privacy protections for its users. Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act (“PDPA”) of Indonesia, and to assist you in making informed decisions when using our Service.
For purposes of this Agreement, “Site” refers to the Company’s website, which can be accessed at zafyre.com
“Service” refers to the Company’s services accessed via the Site, in which users can buy products for educational purposes in healthcare.
The terms “we,” “us,” and “our” refer to the Company. “You” refers to you, as a user of our Site or our Service. By accessing our Site or our Service, you accept our Privacy Policy and you consent to our collection, storage, use, and disclosure of your Personal Information as described in this Privacy Policy.
We collect “Non-Personal Information” and “Personal Information.” Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. Personal Information includes your email address, first name, last name and institutional membership number, which you submit to us through the registration process at the Site. Other terms used in this Privacy Policy shall have the meanings given to them in our Terms of Use or the PDPA (where the context so permits).
To activate the Service, you do not need to submit Personal Information other than your email address, first name, last name, and institutional membership number. To use the Service thereafter, you do not need to submit further Personal Information.
However, in an effort to improve the quality of the Service, we track information provided to us by your browser or by our software application when you view or use the Service, the type of browser you use, the device from which you connected to the Service, the time and date of access, and other information that does not personally identify you. We track this information using cookies or small text files, which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect Non-Personal information about that user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis.
The Company may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser.
In addition to the information provided automatically by your browser when you visit the Site, you will need to create a personal profile to become a subscriber to the Service. You can create a profile by registering with the Service, entering your email address, name, and institution membership number, and creating a username and password. By registering, you authorize us to collect, store and use your email address per this Privacy Policy.
The Site and the Service are not directed to anyone under the age of 13. The Site does not knowingly collect or solicit information from anyone under the age of 13, or allow anyone under the age of 13 to sign up for the Service. In the event that we learn that we have gathered personal information from anyone under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at [email protected]
Personal Information:
Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share your Personal Information with third parties for marketing purposes without your consent. We do share Personal Information with vendors performing services for the Company, such as the servers for our email communications who are provided access to user’s email address for purposes of sending emails from the learning management system vendor and us to enable you to log in an use it for starting your course. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy.
We are careful in our selection of third party service providers, and when we disclose your personal data to such parties, we shall require them to ensure that they are bound by obligations of data protection (pursuant to contracts and/or applicable laws) similar to the obligations as set out in the PDPA.
In general, the Personal Information you provide us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.
We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms of Service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by the PDPA or other laws.
Non-Personal Information
In general, we use Non-Personal Information to help us improve the Service and customize the user experience. We also aggregate Non-Personal Information to track trends and analyze use patterns on the Site. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information, and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers, and other third parties at our discretion.
In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest you check the Site periodically if you are concerned about how your information is used.
Pursuant to the purposes and activities as set out herein, it may be necessary for us to transfer your personal data out of Indonesia for storage, processing and use by Zafyre or its affiliates. You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such personal data are also subject to applicable laws or contractual obligations similar to the obligations as set out in the PDPA.
You have the right at any time to prevent us from contacting you for marketing purposes. When we send promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out on the Site, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.
As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Service. Therefore, this Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.
The Company reserves the right to change this policy and our Terms of Service at any time. We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or placing a prominent notice on our site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.
To the fullest extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorized or unintended use, access or disclosure of your personal data.
You may contact our Data Protection Officer if you have any complaints, enquiries or feedback on this Privacy Policy, your personal data as registered with us, or in relation to our use, retention, disclosure or transfer of your personal data, or if you wish to make any request, in the following manner:
Attn: Zafyre Indonesia Data Protection Officer
Email: [email protected]
All requests for correction or for access to your personal data must be in writing. We will endeavor to respond to your request within 30 days, and if that is not possible, we will inform you of the time by which we will respond to you.
All complaints will be evaluated by us in a timely manner. After we have completed the evaluation, our Data Protection Officer (or duly appointed representative) will respond to the person who submitted the complaint or feedback, with the results of the evaluation.
We may be prevented by law from complying with any request that you make. We may also decline any request that you may make if the law permits us to do so.
The Company reserves the right to change this policy and our Terms of Service at any time. We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or placing a prominent notice on our site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.
The terms and conditions of this Privacy Policy are governed by the laws of Indonesia. In the event of any disputes arising from this Privacy Policy, you must first contact our Data Protection Officer regarding your concern and use your best endeavours to amicably settle any dispute in good faith. We on our part will also use our best endeavours to amicably settle your concerns in good faith. However, if no amicable resolution is reached within 30 days, you agree to submit to the exclusive jurisdiction of the Courts of Indonesia.
If you have any questions regarding this Privacy Policy or the practices of this Site, please contact us by sending an email to [email protected].
Last Updated: This Privacy Policy was last updated on June 10, 2023.