Privacy Policy

Privacy Policy

In order to ensure that the Personal Data is always protected when You access www.blublub.co site and its derivative sites (“Site”) and/or use the features contained therein (“Features”) developed by PT Biru Indah Utama (“Blublub” “We” “Our” “Us”), We are committed to protect Personal Data furtherly set forth under this Privacy Policy. 

This Privacy Policy (“Policy”) constitutes a set of rules that are integral parts of the User Terms and Conditions and Vendor Terms and Conditions, which are made as the basis of Our activities in obtaining and collecting, processing, storage, displaying, distribution and destruction of Personal Data on the Site. The terms and definitions started in capital letters contained under the page of User Terms and Conditions and Vendor Terms and Conditions shall have the same meaning and interpretation as the terms used in this Policy, unless otherwise specified under this Policy. 

By accessing and/or using the Site, You have read, understood, and given approval to Blublub to obtain, collect, store, process, and use Personal Data as set forth under this Policy and are bound to all the terms set forth in this Policy. If You do not approve this Policy, You will not be granted the permission to access and/or use the Site. 

Subject to this Policy, You are also considered to be bound by the User Terms and Conditions and/or Vendor Terms and Conditions whereas this Policy constitutes an inseparable and integral part of the User Terms and Conditions. The invalidity of User Terms and Conditions shall not cause this Policy to become illegal, invalid, and/or not applicable.


1. Acquisition or Collection of Personal Data


1.1 When You access the Site or use the Features contained in the Site, You are directly or indirectly providing Us with Personal Data. For example, when You register by creating an Account in the Site, We shall collect and store Your Personal Data in the form of Your name, email address, password, and other data needed so You can have access to Your account. In addition, We collect Your Personal Data including when You:

a. access the Site and/ or using the Features;

b. registering by creating an Account on the Site;

c. responding the surveys distributed by Us;

d. sending Your review, impressions, messages, critic and / or suggestions to Us, or Vendor;

e. Placing an order for the Activity;

f. contact Us, through the communication facilities that We provide;

g. use the Features that require access permission on Your device; or

h. entering information(s) in relation with Personal Data in any form to the Sites and/ or Feature.

1.2 The Personal Data that We collect is the data that You have provided to Us in the manner that We have previously explained. The Personal Data shall include, among others:

a. data relating to Your personal information, including Your name, address, telephone number, e-mail address, Identity Card photo, photo of You, the type of dive permit You have, or the diving experience You have;

b. Your profile includes age, gender or other data;

c. Emergency contacts

d. Your response to the survey that We gave;

e. History of Order Activity and payment made through Site;

f. Payment details that You insert while processing the Payment through Site;

g. data of real or approximate location such as Internet Protocol addresses, Wi-Fi locations, geo-locations, and others;

h. data in the form of time of each usage activity, including registration, login, transaction, and others;

i. Your data of usage and/ or preferences, including Your interactions in using the Site, stored choices, Activity that You choose or trade as well as the settings selected in the Site;

j. information about the software and hardware that You use to access the Site and/ or use the Feature;

k. data log, including records on the server that received a data such as the IP address of the device, the date and time of access, feature application or page viewed, site work processes and other system activities;

l. interactions, reviews, critics, suggestions and/ or messages from You addressed to Us, other Users, and/or Vendor including everything that is disclosed when You contact Us through the means of communication that We provide or when We provide an  assistants to resolve the problems that arise in connection with the use of the Site ;

m. transaction data, including type, amount and / or description of the service used, delivery address, payment Method used, transaction amount, date and time of transaction, as well as other transaction details;

n. payment data when You perform the payment transaction activities or receive payments through the Site, including but not limited to bank account data, credit cards, virtual accounts, instant payments, internet banking, retail outlets; and / or

o. other things that You do in the Site and/ or Feature and other data that You provide into the Site and/ or Feature.

1.3 You hereby represent and warrant that the Personal Data which You input into the Sites and/ or Features is Your Personal Data based on the actual condition, and You are fully responsible for the Personal Data and You have full authority and/ or personal rights to submit Personal Data to Us, including releasing Us from any civil lawsuits or criminal charges arising from misleading information relating to Personal Data that You input into the Sites and/ or Features.

1.4 We have the right from time to time to request the authentication, verification and/ or updating of Your Personal Data, therefore Your data and information is accurate, complete and up-to-date, including temporarily/permanently terminating or prohibit You to access certain Features optimally in the event that You have not conducted authentication and update Your Personal Data.

1.5 By continuing to access the Sites, using Features, and/ or other Our services, You hereby expressly giving approval to Us to obtain and collect Your Personal Data as set out in Clause 1.1 and 1.2 in this Policy, and this approval is given without any force, in full capacity and conscious state.  


2. Use of Personal Data 


2.1 The Personal Data that We have collected and obtained shall be fully used for Your and Our interests in accordance with this Policy and the Applicable Laws in Indonesia. We may use the Personal Data for, among others:

a. process Your data for Your needs in accessing Sites, using Features;

b. process and / or deliver data / information to the Vendor regarding Your request, make an order for a Activity for You , and / or process Your payment for an order of a Activity ;

c. manage, operate, administer and provide You with the services offered on the Sites;

d. contacting You in regards of the matters relating to Your usage and / or access of the Sites and Features available on the Site, and any questions and / or requests submitted by You through the Site or vice versa;

e. make a personalization and / or adjustment to the Activities that are shown on the Sites in accordance with Your Preference based on your Personal Data with an objective to adjust and maximize your experience in using the Site;

f. communicating with You in connection with the requests for critics and suggestions;

g. inform the information, insight, surveys or interesting program(s) or promotion for You;

h. publish Your review of the Activity, in digital and / or printed format for public access;

i. Sites and/ or Feature development in order to improve Our services, including using information obtained for research, analyzing, product development and testing purposes to improve Your security and comfort in accessing and using the Sites and/ or Feature, and developing Features and/ or new product;

j. business development, service or marketing strategy;

k. measure and improve the experience and satisfaction of the Site users;

l. assist You when filing a report to Us regarding the use of the Site through the communication facilities We provide;

m. conduct monitoring or investigation of suspicious transactions or indicated transactions which containing materials of fraud or violations of User Terms and Conditions, Vendor Terms and Conditions, or Applicable Law, as well as taking necessary actions as response on the outcome of such monitoring or investigation;

n. enforce and applying the User Terms and Conditions and Vendor Terms and Conditions;

o. resolve complaints that We receive, help resolve disputes between Users and Vendors through the Resolution Center, as well as solve problems regarding Site Features in it; and / or

p. for other purposes as notified to you on the time of collection.

2.2 You hereby understand that using Features in the Site requires a process of authenticating, verifying, and/ or updating Your Personal Data. By continuing to access the Site, using Features, and / or other Our services, You hereby expressly give Your approval to the use, utilization and/ or disclosure of Your Personal Data, and state that approval of the use and disclosure of Personal Data for such needs is carried out without being forced, with full capacity, and consciously. 


3. Sharing of Personal Data to Third Parties 


3.1 We understand the confidentiality of Your Personal Data and We are committed not to sell, rent, display, or distribute Your Personal Data without Your prior consent unless otherwise specific in this Policy. We shall only disclose Your Personal Data to third parties with Your agreement. 

3.2 By continuing to access the Site and use the features and other Our services, You hereby given an approval in any form to disclose Your Personal Data and You permit Us to disclose and send Personal Data to Vendor or any third party appointed to help Us provide the services for You including to support the transaction in Sites (“Appointed Third Parties”), and release Us from any loss and damage resulted in Appointed Third Parties failure to secure Your Personal Data. You fully acknowledge that this approval is given without any force, in full capacity and conscious state. 

3.3 We are not able to guarantee the security of Your Personal Data on any third party systems including Vendor systems and Appointed Third Parties systems and We have no control or responsibility for the privacy policies or content of the third parties. Therefore, We recommend You to learn and examine the privacy policies of each third party, so that You understand their terms on handling Your Personal Data.

3.4 We are authorized to disclose Your Personal Data to comply with valid court orders or decisions of legitimate government agencies or the provisions of Applicable Law. If possible and permitted, We shall send You a notification in the event that We are disclosing Your Personal Data.

3.5 You understand and agree that in order to develop Sites, We may use or share Your data and information which do not identify You as an individual, to be processed, developed or cooperated with Appointed Third Parties and other third party. We acknowledge Your privacy, therefore the data and information that we may use and share are aggregate data which do not identify You as an individual. 

3.6 For the avoidance of doubt, the third parties referred to in this Policy are third parties other than Vendors or parties who cooperate with Us for the purpose to support the performance of transactions on the Sites, including but not limited to any third party which provides payment system service. Third parties which provide payment system service may change any time based on Our sole discretion and will be informed from time to time under this Policy. By the time, this Policy is made and published, We are using the services of XENDIT. whereas the privacy policy of XENDIT can be accessed through https://www.xendit.co/en/privacy-policy/


4. Use of Cookies and Third Party Services 


4.1 Cookies are text files that are placed on Your computer for recording purposes. We use cookies to help Us improve Your comfort in accessing Our Sites.

4.2 Cookies shall record Your Personal Data as well as the data that You input into the Sites. For example, if You create an account in the Sites, cookies shall help Us recall specific Personal Data for Your next visit. When You re-access the Sites, the Personal Data that You provided previously will be displayed, so the activation of cookies shall facilitate You in accessing the Sites.

4.3 You may set to disable cookies in Your browser partially or entirely, but when You choose to disable cookies entirely (including significant cookies), You may not be able to access all parts of the Sites and/or Features. 

4.4 In general, the browser has a feature to control most cookies. To find out more about cookies, including but not limited to managing, deleting and seeing which cookies are active, You are encouraged to visit www.aboutcookies.org or www.allaboutcookies.org.

4.5 We reserve the right to use third party services to analyze Personal Data for Us, such as Google Analytics and other third party services that aim to develop Sites and Features, among others, Features that support communication services which provide facilities for Users to interact directly with Vendors. These third-party services include among others the collection of data from Your visits and activities while accessing the Sites and using the Feature.

4.6 Other than payment system service, by the time this Policy is made and published, the service of Appointed Third Parties which we are using is Google Analytics. Google Analytics is a web analytical service offered by Google to track and report sites engagement traffic. Google utilizes the collected data to track and monitor the usage of Our service. The data may be shared to other Google services, Google also may use the collected data to form a personalized advertisement from its own advertising system. We suggest You to read and understand furtherly the practice of privacy and Google terms and condition, through site http://www.google.com/intl/id/policies/privacy/


5. Your Options and Transparency 


5.1 In using the Sites and the Features that We provide, We respect You by providing options that include but are not limited to:

a. You can provide assessments and reviews on the performance of the Activity if it has been successfully carried out, information about it is possible to be seen publicly with Your agreement;

b. You are able to modify Your profile information including date of birth, gender, address, telephone number, email address through the Feature in the Site, if You are registered as an user. 

c. You are able to unsubscribe from the notification of a new Activity is marketed, a variety of the latest promo information, and exclusive offers if You no longer wish for such information.

d. You are able to deactivate Your Account through the setting feature which We provide in the Sites and reactivate Your Account any time, referring to the procedure We establish from time to time. 


6. Storage and Deletion 


6.1 Your Personal Data that You input into the Site as well as We obtain based on the provisions of Clause 1 of this Policy shall be stored with security procedures and facilities in accordance with the provisions of the law for the period specified in the provisions under the Prevailing Laws in Indonesia.

6.2 We do not provide any means for You to delete Your Account in Our Sites and Features. If You wish to delete Your Account, You can submit a request for deletion of the account to Us by including the reason for deletion through the communication facilities mentioned in this Policy. In the event that You delete Your account, You consciously understand the consequences that You cannot use Features and Sites or other Blublub’s services because You are no longer registered as a User or Vendor. Please be informed that even though You are no longer a User or Vendor registered with the Sites, Your Personal Data can still be stored for the required period based on the provisions of the Applicable Law.

6.3 We have the authority to delete Your own Account based on Our terms, based on court decree or judgment, and/ or in accordance with law. We shall notify You by email regarding the deletion of Your Account under this authority.

6.4 We have the authority to delete Your Personal Data based on Your Written request or at Our discretion, in the manner that We specify but remain subject to the Indonesian Prevailing Laws.


7. Additional Rights 


7.1 Specified for those who are subject to General Data Protection Regulation (“GDPR”),  there are additional rights We provided for You whereas We provide the facility for You to fix, modify, delete, or limit the usage of Your Personal Data. 

7.2 If You intend to gain further information on the kind of Personal Data which We store or if You intend for the specified Personal Data to be deleted for Sites and systems We develop, You may contact Us through Our Contact feature or other means of communications We provide from time to time. 

7.3 Under specific circumstance, as stipulated in GDPR, You have additional rights as listed below: 

a. The right to access, amend, and delete Your information that We own. Whenever deemed possible, You may access, amend, or submit a request for deletion of Personal Data directly through the Account setting. If you are unable to do so, You may notify Us so We can further assist You. 

b. The right to modify. You are entitled to modify your information if the specified information is no longer accurate or complete. 

c. The right of refusal. You may refuse to have Your Personal Data processed by Us. 

d. The right of limitation. You are entitled to submit a request that We limit the processing of Your personal information. 

e. The right of data portability. You are entitled to be given a copy of information that We own on behalf of You in a structured format, machine-readable and widely-known general format. 

f. The right to revoke approval, You are entitled to revoke your approval in any time We are bound by Your consent to proceed Your personal information.  

7.4 You need to know that We may ask for verification of Your identity before we respond to Your request. 


8. Limitation of Liability


8.1 You are responsible for security and implement appropriate measures in safeguarding Your Personal Data, such as, restricting access, creating strong passwords, protecting passwords, and/ or protecting One-Time Password (OTP).

8.2 We are not responsible for the exchange and/ or provision of Your Personal Data that You do personally, including what You do through the Site.

8.3 Our Sites may contain links to other websites. In case you use such links, you should understand that We do not have any control on such websites and / or Site, therefore you understand and warrant that we are not / shall not be held accountable on the privacy policies of the sites / Site of the other third party, based on such links and recommend You to read the privacy policy  of each site / Site You visit that collects Personal Data.

8.4 We are only responsible for the protection and security of Your Personal Data to the extent that Personal Data is stored in a system developed and managed by Us and We at any time shall perform and take any reasonable steps that are required to protect and safeguard Your Personal Data. By continuing to access the Site, using Features, and / or other Our services, You waive the rights to administer a claims, losses, demands and lawsuit that You may have in the event of failure of Personal Data protection arising from a part of negligence committed by Yourself in maintaining the security and confidentiality of Personal Data and/ or as a result of actions by third parties who attempt to obtain Personal Data in an illegal manner.

8.5 We are not responsible for the originality, authenticity, validity, accuracy, completeness of the Personal Data You provided. 


9. Miscellaneous


9.1 We always try to provide the best services for You in accessing the Site and using Our Features therefore We have the right to make changes to this Policy to perform adjustment for business developments and applicable legal provisions. Changes to this Policy shall from time to time be uploaded to the Site so that You can read the changes from this Policy. If changes to this Policy are material to personal Site data and information, We shall notify You before the changes take effect. By continuing to access the Site, using Features, and / or other Our services, You declare that You have read, understood and agreed to be bound by the changes of this Policy.

9.2 If there are provisions or parts of this Policy that are against the law, cannot be applied or become invalid, then the provisions or such parts shall be deemed has been removed from this Policy and We will adjust such provisions so that it can be performed, with such, other provisions of this Policy shall remain in full force.

9.3 In the event of a change of controller or a change in ownership of all or part of Our business, including the Site, due to the performance of a merger, consolidation, acquisition, joint venture, transfer, bankruptcy, and / or other corporate actions, Your Personal Data may /shall be part of the transfer based on such corporate actions.

9.4 This Policy may be translated to other languages ​​besides Indonesian which is provided by Us. There is a possibility that some part in this Policy have different meaning, purpose, or interpretation when translated into other languages. If there are differences between the Indonesian versions and the foreign language versions, the Indonesian version shall prevail, and You are advised to refer to the Indonesian version.


10. Contact Us


You may deliver questions, critics and suggestions, complaints, or reports related to Personal Data by contacting Us through email hello@blublub.co or telephone number at +62 811 86 9293. All correspondence between You and Us may be noted or recorded by Us for Our interest.


Blublub Indonesia