Introduction to Privacy Policy

Welcome to SERMORPHEUS platform directly operated by PT. Likuid Jaya Inisiasi (“SERMORPHEUS”/ ”PLATFORM”). SERMORPHEUS is committed to be responsible based on laws and regulations on privacy applicable in Indonesia (“Privacy Law”) and is fully committed to respect privacy rights and issues of all Members / Verified Members registered in our platform.

The following Privacy Policy provides an explanation of how SERMORPHEUS, along with terms of use of SERMORPHEUS platform as set out in “Terms & Condition” and other Information stated in SERMORPHEUS website, stipulates the basis in collecting, storing, using, processing, controlling, transferring, disclosing, and protecting Personal information of Member / Verified Member which SERMORPHEUS has obtained and collected from Member / Verified Member consisting of personal data of Member / Verified Member, which Member / Verified Member uses while performing registration, accessing, and using services in SERMORPHEUS platform.

It is important for Member / Verified Member to be aware of and understand this Privacy Policy along with other applicable information, which will be used as the basis of management of personal data of Member / Verified Member. This Privacy Policy (“Privacy Policy”) is designed to help Member / Verified Member to understand how SERMORPHEUS collects, uses, discloses, and/or processes personal data a Member / Verified Member entrusts to SERMORPHEUS and/or which SERMORPHEUS has about Member / Verified Member, whether at present or in the future, and to help Member / Verified Member to make the right decision prior submitting personal data of Member / Verified Member to SERMORPHEUS. By continuing to access and always using SERMORPHEUS Services, the Member / Verified Member is hereby deemed to agree with all Privacy Policies stated in SERMORPHEUS platform along with the amendments thereto.

IN THE EVENT THAT MEMBER / VERIFIED MEMBER DOES NOT PERMIT THE PROCESSING OF PERSONAL DATA OF MEMBER / VERIFIED MEMBER AS EXPLAINED IN THIS PRIVACY POLICY, WE DO NOT ADVISE TO USE SERMORPHEUS SERVICES OR TO ACCESS SERMORPHEUS PLATFORM. In the event that SERMORPHEUS makes any amendment to SERMORPHEUS Privacy Policy, SERMORPHEUS will post such amendment or the Privacy Policy which has been amended on SERMORPHEUS Platform. SERMORPHEUS has full rights to amend this Privacy Policy at any time without requiring approval from Member / Verified Member but by referring to the applicable laws and regulations.

This Privacy Policy includes matters as follows:

1.   Personal Information obtained and collected by SERMORPHEUS

1.    Personal Information is any form of Information whether or not recorded in material form, and based on such information, the identity of a person can be directly seen or identified and reasonably known and can be directly ensured by an organization or entity which collects such information, or when combined with other information, which can directly or indirectly identify a person, and which can or may be accessed by an authorized Party in case any issue arises.

1.    While Member / Verified Member is using SERMORPHEUS Services, SERMORPHEUS may collect Personal Information of Member / Verified Member, including but not limited to the following:

a.     Identity data, such as name, gender, profile picture, and date of birth;

b.    Contact data, such as delivery, electronic mail address, and phone number;

c.     Account data, such as bank account and payment details;

d.    Transaction data, such as details of order or purchase of crypto asset or history of transactions performed by Member / Verified Member while using SERMORPHEUS platform;

e.     Technical data, such as Internet Protocol (IP) address, login data, type and version of browser, settings of time and location cone, type and version of browser plug-in, operating system and platform, identity of device and device-related matters while using SERMORPHEUS platform;

f.     Profile data, such as username and password, purchase, order or preference intention, and response to reply and survey;

g.    Usage data, such as information on how Member / Verified Member uses SERMORPHEUS platform, products, and Services;

h.    Location data, namely the method used by Member / Verified Member while taking and sharing location with SERMORPHEUS in the form of picture or video and uploading them to SERMORPHEUS platform;

i.      Biometric data, namely sound file when Member / Verified Member uses the feature of face or other body part and sound or others which become the feature of device by uploading it to the platform;

j.      Marketing and correspondence data, namely matters related to preferences of Member / Verified Member in receiving marketing materials from SERMORPHEUS and third parties and communication preferences of Member / Verified Member.

1.      Member / Verified Member agrees not to submit any information which is inaccurate or misleading, and Member / Verified Member agrees to inform about the inaccuracy or change of such information. SERMORPHEUS has the right of discretion to require further documentation to perform verification of information submitted by Member / Verified Member.

1.   Use of Data by the platform and ability of SERMORPHEUS to receive personal data of Member / Verified Member in the situations as follows:

1.    When Member / Verified Member makes account in SERMORPHEUS platform or updates SERMORPHEUS account, including therein username, e-mail address, phone number, password, address, etc.;

2.    When Member / Verified Member uses a feature or function available on SERMORPHEUS platform;

3.    When Member / Verified Member registers for a service of SERMORPHEUS platform or purchases a crypto asset product available on SERMORPHEUS platform;

4.    When Member / Verified Member records and uploads a user-generated content to SERMORPHEUS platform;

5.    When Member / Verified Member uses the chatting function on SERMORPHEUS platform;

6.    When Member / Verified Member participates in a competition, promotion, or survey;

7.    When Member / Verified Member participates in an activity or campaign on SERMORPHEUS platform;

8.    When Member / Verified Member logs into their account or interacts with SERMORPHEUS through external service or application;

9.    When Member / Verified Member interacts with us off-line, including when Member / Verified Member interacts with outsourced employees of SERMORPHEUS off-line.

Use of Data

SERMORPHEUS may use all or some data obtained and collected from Member / Verified Member as referred to in the previous section for matters as follows:

1.    To identifying and register Member / Verified Member as user and to administer, verify, deactivate, or manage account of Member / Verified Member;

2.    To facilitate or enable any verification which we consider necessary before SERMORPHEUS provides services to Member / Verified Member or before we register Member / Verified Member as user, including the Know Your Customer process;

3.    To enable SERMORPHEUS to provide, process, and facilitate, orders and payment transactions;

4.    To facilitate Member / Verified Member Service in implementing instruction of Member / Verified Member, dealing with or responding to any question raised by (or supposedly raised by) Member / Verified Member and/or on behalf of Member / Verified Member.

5.    To communicate with Member / Verified Member and send information in connection with the use of platform, including but not limited to information about any update as well as support which may be required from time to time to ensure continuity of SERMORPHEUS Services;

6.    To inform Member / Verified Member about any update to SERMORPHEUS platform or update to services provided;

7.    To monitor and analyze activity, behavior, and demographic data, including habits and responsiveness of SERMORPHEUS to various services available on the platform;

8.    To send Member / Verified Member direct or targeted marketing communication, advertising, promotion, survey, and special offer or promotion;

9.    To use information obtained from Member / Verified Member for the purpose of research, analysis, development, and testing of product in order to improve safety and security of services on the Website, as well as for developing new feature and product;

10. To perform monitoring or investigation of suspicious transactions or transactions indicated of containing the element of fraud or violation against the Terms and Conditions or the applicable legal provisions, as well as to take the necessary actions as follow-up of the result of monitoring or investigation of such transactions;

11. In certain situations, SERMORPHEUS may need to use or disclose User’s data for the purpose of law enforcement or for the fulfillment of requirements of the applicable laws and regulations, including in the event of any dispute or legal proceeding between Member / Verified Member and SERMORPHEUS;

12. Any other purpose which SERMORPHEUS will inform Member / Verified Member when obtaining approval from Member / Verified Member is collectively referred to as (“Purpose” );

13. Due to Purpose, SERMORPHEUS will / may collect, use, disclose, or process personal data of Member / Verified Member depending on the situation encountered, and it is possible that such purpose is not state above. However, SERMORPHEUS will inform Member / Verified Member about such other purpose of that kind when obtaining approval from Member / Verified Member, except for data processing which applies without approval from Member / Verified Member permitted by the Privacy Law.

Disclosure of Personal Data of Member / Verified Member

SERMORPHEUS guarantees that there is no sale, leakage, transfer, distribution, or lending of personal data of Member / Verified Member to other party, without permission from Member / Verified Member, except in the event of occurrence of the following matters or events:

1.    When there is requirement for disclosure of data of Member / Verified Member to other party assisting SERMORPHEUS in providing services on SERMORPHEUS platform and processing any form of activities of Member / Verified Member on SERMORPHEUS platform, including but not limited to transaction process, payment verification, etc.;

2.    SERMORPHEUS may provide and make available relevant data or information to SERMORPHEUS business partner in accordance with rules of approval from Member / Verified Member to use business partner’s services, which are included in the application, website, or other platform which integrates API or its services, or business partner with whom SERMORPHEUS has cooperated to deliver forms of promotional services, contest, or other dedicated matters;

3.    Other matters required by SERMORPHEUS such as banking, payment, and other services with Member / Verified Member, in this case including settlement of obstacles and other matters;

4.    SERMORPHEUS may provide relevant information to vendor, consultant, marketing partner, research firm, or similar service providers;

5.    SERMORPHEUS may share information of Member / Verified Member to its subsidiaries and affiliates to help in maximizing or providing services as well as data processing for and on behalf of SERMORPHEUS;

6.    SERMORPHEUS discloses data of Member / Verified Member in an effort of complying with and fulfilling legal obligations and/or based on valid request from Similar Law Enforcement Agencies and Apparatus.

1.   Storage and Deletion of Information

1.    Personal Information of Member / Verified Member will only be stored as long as necessary for fulfilling the purpose of its collection, or as long as such storage is required or allowed by the applicable laws and regulations. SERMORPHEUS will stop storing Personal Information, or delete the purpose of linking such Personal Information to you as an individual, as soon as it is considered that the purpose of collection of such Personal Information does not require storing Personal Information anymore and the storage is not necessary anymore for business or legal purposes.

2.    Personal Information of Member / Verified Member collected by SERMORPHEUS may be stored, transferred, or processed by a third party service provider. SERMORPHEUS will take reasonable effort to ensure that all of such third party service providers provide a level of protection equivalent to the commitment of SERMORPHEUS based on this Privacy Policy.

3.    Personal Information of Member / Verified Member may also be stored or processed outside the country of the Member / Verified Member by a party working for SERMORPHEUS in other country, or by third party service provider, vendor, supplier, partner, contractor, or affiliate of SERMORPHEUS. In this case, SERMORPHEUS will ensure that such Personal Information continues to be a subject of level of protection equivalent to those required in the law of the country (and, in any case whatsoever, in line with our commitment in this Privacy Policy).

4.    SERMORPHEUS will store and process Information as long as the account of Member / Verified Member is active.

1.   Cookies

1.    Cookies are small data storage in a computer or other device when Member / Verified Member browses and/or visits SERMORPHEUS.

2.    Cookies are identifier transferred to computer or mobile device of Member / Verified Member which enables us to identify the computer or device of Member / Verified Member and informs SERMORPHEUS about how and when Services or Platform is used or visited, by how many persons, and to trace activities on the SERMORPHEUS Platform. SERMORPHEUS may link information cookies to personal data. Cookies are also linked to information on transactions of Member / Verified Member and Cookies are also used to deliver specific content in accordance with the interests of Member / Verified Member and to monitor the use of SERMORPHEUS Services.

3.    Member / Verified Member will automatically receive Cookies when the Computer or Device of Member / Verified Member uses or browses SERMORPHEUS platform. However, Member / Verified Member may choose to modify or choose to refuse the Use of Cookies through web or browser setting preferences in the device or computer of Member / Verified Member.

4.    SERMORPHEUS uses Google Analytics (“Feature”), in which data obtained from the use of such Feature include IP address of Member / Verified Member, type of device of Member / Verified Member, etc. (“Data”). Such data are used by SERMORPHEUS for the development of platform and Content of SERMORPHEUS as well as advertisement. Member / Verified Member may choose to be inaccessible by Feature by means of downloading Google Analytics Opt-Out Add-on on web browser of Member / Verified Member.

5.    SERMORPHEUS may use and provide information on data of Member / Verified Member SERMORPHEUS obtained from the Use of Cookies by Member / Verified Member to a third party, such as location data, advertising identifier, or e-mail address used for advertisement, including but not limited to for promotional and advertisement purposes in which such data cannot personally identified.

6.    The use of Cookies can be controlled by Member / Verified Member through setting preferences of web browser used by Member / Verified Member, namely by making modification or choosing to refuse the Use of Cookies. However, by making such setting, performance of service during access to SERMORPHEUS platform may be affected, such as certain functions and pages on SERMORPHEUS Website unable to perform optimally for the provision of services to Member / Verified Member.

1.   Personal Data Protection of Member / Verified Member

1.    SERMORPHEUS applies various safety measures and strives to ensure Personal Data of Member / Verified Member in SERMORPHEUS system. Personal data of Member / Verified Member are kept behind a secure network and only accessible by a small number of employees having special access right to the system. Nevertheless, the absence of absolute guarantee or security is unavoidable.

2.    SERMORPHEUS will keep personal data in accordance with the Privacy Law and/or other applicable laws. Namely, SERMORPHEUS will destroy or anonymize personal data of Member / Verified Member when SERMORPHEUS reasonable deems that (i) the purpose of personal data which have been collected is not functioned anymore by the storage of such personal data; (ii) the storage is not necessary anymore for any legal or commercial purposes whatsoever; and (iii) there is no instruction letter legitimating further retrieval of personal data. In the event that a Member / Verified Member stops using SERMORPHEUS Platform, or the license of a Member / Verified Member to use Platform and/or Services is terminated or revoked, SERMORPHEUS may continue to keep, use, and/or disclose personal data of Member / Verified Member in accordance with the Privacy Policy and obligations of SERMORPHEUS under the Privacy Law. Subject to the applicable law, SERMORPHEUS may securely dispose personal data of Member / Verified Member without any prior notification to Member / Verified Member.

1.    Information on children

Services are not intended for children aged less than 18 years. SERMORPHEUS does not intentionally collect or store personal data or any non-personal information from any person aged less than 18 years and any part of Platform or other Services of SERMORPHEUS is not intended for children aged less than 17 years. As parent or legal guardian, please do not give permission to children under your care to submit personal data to SERMORPHEUS. In the event that personal data of children aged less than 18 years under your care are opened to SERMORPHEUS, you hereby consent to the processing of personal data of the child and accept and agree to be bound to this Privacy Policy on behalf of such child. SERMORPHEUS will close any account used exclusively by such children and will eliminate and/or delete any personal data SERMORPHEUS believes to be sent without consent of parent or legal guardian by a child aged less than 18 years.

1.   Disclaimer of Security and Third Party Website

1.    SERMORPHEUS DOES NOT GUARANTEE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THE MEMBER / VERIFIED MEMBER SUBMITS ON A THIRD PARTY WEBSITE. SERMORPHEUS has indeed implemented a variety of security measures to maintain the safety of personal data of Member / Verified Member with or under the control of SERMORPHEUS. Personal data of Member / Verified Member are kept behind a secure network and only accessible by a limited number of persons having special access right to the system, who are obligated to keep the confidentiality of such personal data. In the event that the Member / Verified Member places an order or accesses personal data, SERMORPHEUS offers the use of secure server. All personal data or sensitive information submitted by Member / Verified Member are encrypted into our database and can only be accessed as stated above;

2.    In an effort of providing Member / Verified Member with increasing value, SERMORPHEUS may choose various third party websites to be linked to, and to frame them in the Platform. SERMORPHEUS may also participate in co-branding and other relationship to offer e-commerce as well as other services and features to SERMORPHEUS visitors. All of these linked websites have separate and independent privacy policy and security settings. Even if a third party is affiliated to SERMORPHEUS, SERMORPHEUS has no control over these linked websites, since each of them has privacy and data collection practices separated from SERMORPHEUS. It is possible that data collected by SERMORPHEUS co-branding partner or third party website (even if it is offered on or through SERMORPHEUS Platform) are not received by SERMORPHEUS;

3.    Therefore, SERMORPHEUS is not responsible or accountable for content, security settings (or the absence of security settings), and activities of these linked websites. These linked websites are only for the convenience of Member / Verified Member, and therefore Member / Verified Member accesses them at the Member / Verified Member’s own risk. Nevertheless, SERMORPHEUS strives to protect the integrity of SERMORPHEUS Platform and links placed on each website, and therefore, SERMORPHEUS welcomes any feedback on these linked websites (including, but not limited to, in the event that certain link is not functioning).

1.    Update of Privacy Policy

SERMORPHEUS may update this Privacy Policy at any time. SERMORPHEUS hereby advises Member / Verified Member to read carefully and always recheck every page of this privacy policy from time to time to find out about any changes which have been made to this Privacy Policy.

1.    Questions, Issues, or Complaints

If Member / Verified Member have any questions, issues, or complaints regarding SERMORPHEUS privacy policy practices, please contact us by e-mail at [email protected]