While the Member use the Application, We collect Member Personal Data which includes electronic information in the form of text, sound, images, and other similar forms in which the intention is to process Member transactions, manage. and expedite the process of utilizing the Application, as well as other purposes regulated in the Terms and Conditions of the Metland Card Loyalty Member Program in conjunction with the Application permitted by applicable rules and/or laws and regulations. Member Personal Data collected shall include:

2.1.  Member Personal Data provided by the Member independently, including but not limited to           data provided by Members when:

        2.1.1.  Creating or updating an account on the Application which includes the Member's                          name (both real name and username), password, address, telephone number, email                    address, photo, and others.

        2.1.2.  Contacting us regarding the use of the Application and consumer services.

        2.1.3.  Submitting the necessary Personal Data related to the Metland Card Loyalty Member                    Program.

        2.1.4.  Filling out the survey sent by us.

        2.1.5.  Using any services or features in the Application according to the Terms and                                  Conditions in the Application.

        2.1.6.  Using features that require permission to access Member devices in the Application.

2.2.  Member Personal Data contained in the Application when the Member uses the Application           or when registering to use the Application, including but not limited to:

        2.2.1.  Member identity data such as ID Card/Passport/Temporary Stay Permit Card.

        2.2.2.  Data in the form of the every time of Member activity, including registration, login,                          transaction activities, and etc.

        2.2.3.  Mobile terminal identifier, access information to the Application, and other information                    based on the Member's use of the Application; and/or

        2.2.4.  Log data, including records on servers that receive data such as device IP                                    addresses, date and time of access, Application features or pages viewed,                                    Application work processes and other system activities, browser type, and/or third                          party applications or services that Member use before using the Application.

        2.2.5.  Member usage or preference data, including Member interaction in using the                                Application, saved options, and settings selected by the Member. This data is                                obtained using cookies, pixel tags, and similar technologies that create and maintain                    a unique identifier.

        2.2.6.  Device data, including the type of device used to access the Application, including                        hardware model, operating system and version, software, file name and version,                            language choice, unique device identifier, advertising identifier, device serial number.

2.3.  Member Personal Data obtained from other sources, including:

        2.3.1.  Management, including data and information related to Member Residential                                  ownership and other information that may be requested and submitted by Members                      in connection with a transaction with Management and/or Management Group.

        2.3.2.  Marketing and advertising service providers, large-scale data analysts, artificial                              intelligence and other third party service providers; and

        2.3.3.  Publicly available sources.

        2.3.4.  Business partners that provide services that support and/or facilitate Member to                            create or access our accounts on the Application, such as social media services,                          advertising, or sites/applications that use this Application.

        2.3.5.  Business partners who participate in developing and providing services in the                                Application to Member, including Application infrastructure provider partners, and                          other partners.

        2.3.6.  Business partners who provide services that support and/or facilitate Member in                            creating or accessing our accounts on the Application, such as social media services,                    advertising, or sites/applications that use this Application.

        By agreeing to this Privacy Policy, the Member hereby declares and guarantees that the               Member has permitted the collection, storage, transfer, management, and delivery of all               Personal Data that has been submitted to us before the Member starts using the                           Application. With this, the Member releases us from all legal responsibilities and shall not             make any claims or lawsuits in connection with all matters relating to the member's                       Personal Data in this Application.

2.4.  If for any reason the Member conveys, sends, distributes or in any other way provides                   access to us a personal information belonging to a third party, the Member hereby declares         and guarantees that the personal information belonging to the third party has been                       obtained, sent, submitted, or in any way accessed is opened with the approval of the third             party and in a manner that is in accordance with the laws and regulations prevailed in the             Republic of Indonesia. Member hereby states that they are fully responsible and frees us             from all responsibility for submitting, sending, distributing or disclosing personal information         related to third parties submitted to us.

2.5.  The application is not intended for children under the age of 17. Parents or legal guardians           (except for parents/guardians who register their children as additional cards), should not               give permission for children who are in your care to submit personal data to us. In the event         that personal data from children under the age of 17 under your care is disclosed to us, you         hereby consent to the processing of the child's personal data as well as accept and agree to         be bound by this Privacy Policy on behalf of the child.

We may use the Member Personal Data obtained and collected in this Application in whole or in part for the following matters:

3.1.  Using data obtained from Member for product marketing purposes and measuring the                   advertising effectiveness for a product promotion including to improve the security of                     services on the Application.

3.2.  Informing Member regarding products, services, promotions, information on the latest                   developments, events, and others, either through the Application and other media. We may         use Member personal data to promote and process sweepstakes and provide lottery prizes           and deliver relevant content about our services and our business partners which are part of         the Metland Card Loyalty Member Program.

3.3.  Processing all forms of requests, activities, and upload transactions made by Member                   through the Application, which are related to the Metland Card Loyalty Member Program.

3.4.  Providing features to provide, realize, maintain, and improve our products and services,               including:

        3.4.1.  Offer to obtain, provide, or facilitate reward, parking, directory services, or other                            products through the Application including providing information about events and                          advertisements for products or services provided by us and/or other companies                            appointed by Management.

        3.4.2.  Enables features to personalize or personalize Member accounts on the Application.

        3.4.3.  Implementation of internal activities needed to provide and maximize services on                          Applications, such as solving software problems, bugs, operational problems, as well                    as conducting data analysis, testing, and research, to monitor and analyze usage                          trends and activities and other things that support Application services.

3.5.  Helping Member when communicating with customer service or application consumer                   services, including:

        3.5.1.  Checking and solving Member problems in using the Application.

        3.5.2.  Directing Member questions to the right customer service or customer service                                officers to solve problems.

        3.5.3.  Overseeing and improving the Application's customer service response.

3.6.  Product improvement and development as well as quality of customer service and others.

3.7.  Monitoring or investigating suspicious transactions or those indicated to contain elements of         fraud or violations of the Application’s Terms and Conditions related to the Metland Card               Loyalty Member Program by taking the necessary actions as a follow-up to the results of the         monitoring or investigation of the transaction.

3.8.  Contacting Member via email, telephone, and others, including for notifications,                             authentication, providing information about products and services managed by us and                   tenants as well as helping and/or completing transaction processes and problem solving               processes.

4.1.  We guarantee that there will be no sale, transfer, sharing or lending of Member Personal               Data to other third parties, without the permission or approval of the Member, except in the           following cases:

        4.1.1.  For the benefit of Management and/or Management Group as controllers of Personal                    Data as well as partners or other third parties from Management and/or Management                    Group as those who assist in providing Application services, data processing, and                        handling all forms of Member activity in Applications, including processing                                      transactions, operations and membership verification and the Metland Card Loyalty                      Member Program.

        4.1.2.  In carrying out coordination with our business partners in connection with risk                                mitigation, solving obstacles or other matters that we deem necessary in protecting                      the interests of Member.

        4.1.3.  As the provision of information needed by vendors, consultants, marketing partners,                      and research institutions, or providing similar services for other purposes regulated in                    Article 3 (Member Personal Data Usage).

        4.1.4.  We may provide the necessary Personal Data to our business partners in order to                        facilitate the use of business partner services by Member, including other                                      applications or websites that have been integrated or connected with the Application                      or its services, or business partners who have collaborated with us in carrying out                          promotions, sweepstakes, or services related to the Application.

4.2.  Member agrees and gives approval to Us to transfer, disclose, operate, and process                     Member Personal Data outside the territory of the Unitary State of the Republic of Indonesia         to the extent permitted by applicable laws and regulations.

4.3.  We may also disclose Member Personal Data in order to comply with legal provisions                   and/or statutory regulations, should there is a valid request from law enforcement officials             and in connection with a legal process in court or due to a court decision that has                         permanent legal force.

4.4.  We shall take all reasonable and necessary steps to protect Member Personal Data which           is disclosed or transferred to any third party with a standard of protection equal to the                   provisions of this Privacy Policy.

We shall not store Member Personal Data longer than necessary as described in fulfilling the purpose of use set forth in Article 3 (Member Personal Data Usage) of this Privacy Policy and as required by legal provisions and/or applicable laws and regulations that apply with retention of Personal Data.

Member may ask us to delete Member Personal Data as needed accompanied by valid reasons and supporting data including to contact us in connection with the use of Personal Data at the following address:

PT. Metropolitan Global Management

M Gold Tower Office Wing Suite ABCGH Lt. 12 & A-H Lt. 15

Jl. Letkol M. Moeffreni Moe’min, Pekayon Jaya

Bekasi Selatan, Kota Bekasi

Email: info@metlandcard.com

We shall constantly ensure that the Member's Personal Data is fully protected to the best of our ability, but if the Member's Personal Data is leaked due to actions beyond our control, the Member allows us to notify the Member via electronic means regarding the leak of the Personal Data. As long as it can be proven that the leakage of the Member's Personal Data is beyond our control, the Member hereby releases us from all civil and criminal charges in the future for the leakage of Personal Data caused by actions beyond our control.

We, at our own discretion, may make changes or updates to this Privacy Policy from time to time. And these changes shall apply in any way, including but not limited to, by installing a revised version of the Privacy Policy on the Application. In this case, the Member may see the provisions in the Application to stay aware of changes that may affect Member Personal Data. Use of the Application by the Member constitutes the Member's ongoing agreement to be bound by this Privacy Policy and its changes as amended from time to time. We reserve the right to make any changes we deem appropriate to the Privacy Policy.

9.1.  Mobile devices in general (iOS, Android, and etc.) have settings so that the Application                 cannot access certain data without the approval of the Member. The iOS device will provide         a notification to the Member the first time the Application requests access to the data, while           the Android device will provide a notification to the Member the first time the Application is             loaded and the Member is asked to give approval to the notification the first time the                     Application requests access to the data (for iOS Devices) or when the Application is first               loaded (for Android devices).

9.2.  Members may access and change information in the form of email addresses, telephone               numbers, dates of birth, gender, address lists, payment methods and bank accounts if the             Application provides these features as well as other Personal Data through the Settings               feature in the Application if the Application has a payment feature.

9.3.  As far as permitted by the provisions of the applicable laws and regulations, Member may             contact us to withdraw consent for the acquisition, collection, storage, management and use         of Member Personal Data. In this case, the Member understands the consequences that the         Member cannot use the Application service or other related company services.

10.1.  Cookies are a collection of information that contains track records and activities when                   browsing a website which will automatically take place on a Member's device that performs           a function in storing Member preferences and configurations while visiting a website.

10.2.  Cookies are not intended to be used when accessing other data that the Member has on               the Member's Cellular device, other than what the Member has agreed to submit.

10.3.  Although the Member's Cellular device will automatically receive cookies, the Member can           make choices in making modifications through the Member's browser settings, namely by             choosing to refuse cookies (this option may limit optimal service when accessing the                     Application).

10.4.  We may use features provided by third parties in order to improve Application services,                 including among other things, customizing, and serving advertisements to each Member               based on interest or visit history.

By using and/or clicking agree on the form or column of agreement to this Privacy Policy, the Member hereby expresses their consent for us to use Member's Personal Data in accordance with the provisions of this Privacy Policy.