ENGLISH INTRODUCTIONSportsmedia Indonesia ("SMI") and PT. Fave Global Konsultan ("FaVe") are committed to protecting your personal data and respecting your privacy. This privacy policy explains how we collect, use, and safeguard your personal information in accordance with the applicable laws of the Republic of Indonesia, including Law No. 27 of 2022 concerning Personal Data Protection ("PDP Law") . It also outlines your rights under these laws and how you can exercise them. We will only process your personal data as described in this policy or as permitted by law. In this policy, ‘you’ refers to party leaders, individuals making enquiries or bookings, students and accompanying staff, parents/guardians, and adult group travellers. WHO WE ARESMI, a business unit of FaVe, is an Indonesian consulting company offering talents management, educational tours, group travel, and bespoke travel arrangements. We act as the data controller for the personal data you provide to us, which means we determine the purposes and means of processing your personal data.
WHAT IS PERSONAL DATA?Personal data refers to any information that relates to an identified or identifiable individual. This includes, but is not limited to, names, contact details, passport information, and health-related data. Processing refers to any operation performed on personal data, such as collection, storage, use, disclosure, and deletion. We process personal data to respond to enquiries, provide quotes, administer bookings, and deliver travel services. WHAT DATA WE COLLECTWe may collect and process the following types of personal data to enable us to respond to an enquiry, provide a proposal and quote, administer and fulfill your booking or send you promotional and marketing material:
Contact Information (name, position, address, email, phone number of group leader)
Travel Documentation (name, DOB, passport details, visa information)
Health and Dietary information (medical conditions, allergies, dietary requirements)
Emergency contact details
Special category data
Depending on the nature of your trip, we may also collect additional data such as height, shoe size, and weight (for ski trips), musical biographies and photographs (for concert tours), and cultural or physical requirements (for homestays). SPECIFIC PERSONAL DATASpecific Personal Data may include health information, biometric data, genetic data, personal financial information, criminal records, and other categories of personal data designated by applicable laws. HOW WE COLLECT YOUR DATAWe collect data through various channels including booking forms, online submissions, email and telephone communications, social media, events and conferences, third-party group leaders or organisers, and our website. We may also receive personal data from third parties when required to fulfil our contractual obligations, such as when you are listed as a passenger on a confirmed tour or providing a service as part of a tour. LEGAL BASIS FOR PROCESSINGWe process your data under the following lawful bases:
Consent
Performance of a Contract
Compliance with Legal Obligations
Protection of Vital Interests
Legitimate Business Purposes as permitted by applicable laws
HOW WE USE YOUR DATAYour data is used to organize and deliver travel services, communicate with you regarding your booking, provide customer support, ensure your safety and wellbeing during travel, and send marketing communications (if consent is given). We may also use your data to improve our services, conduct feedback surveys, and manage our internal operations. We do not knowingly collect personal data from children except through parents, legal guardians, schools, or authorized group leaders. AUTOMATED DECISION MAKINGWe do not use automated decision-making or profiling that produces legal or similarly significant effects. SHARING YOUR DATAWe may share your data with airlines, accommodation providers, transport companies, insurance providers, tour guides, local partners, activity and excursion providers, IT and payment processing providers, and regulatory authorities. We ensure all third parties only process your data for specified purposes. We only provide third parties with the personal data they require in order to deliver their services and take appropriate steps to ensure they keep it secure. INTERNATIONAL DATA TRANSFERSWhere necessary, your data may be transferred outside Indonesia. Organizations outside Indonesia may not be subject to the same level of controls in regard to data protection as exist within the Republic of Indonesia. We ensure appropriate safeguards are in place. Personal data will not be transferred to a country outside the Indonesia unless it meets the required data protection standards. Transfers may occur when booking international travel services required by contract or complying with legal obligations in other jurisdictions. Where required by Indonesian law, we will ensure that international transfers are carried out with appropriate safeguards and in accordance with applicable legal requirements. DATA SECURITYWe implement robust technical and organizational measures to protect your data, including secure servers, encrypted communications, access controls, staff training, and regular audits. These measures are appropriate to the harm that might result from unauthorised processing or accidental loss. We also conduct regular reviews of our data protection practices to ensure ongoing compliance taking into account the nature, scope, context, and purposes of processing . BREACH NOTIFICATIONWhere required by applicable law, we will notify affected individuals and relevant authorities of eligible personal data breaches. MARKETING COMMUNICATIONSWe may send you marketing communications about our services if you have opted in to receive them. You may withdraw your consent at any time by clicking the "Unsubscribe" link in our emails or by contacting us directly. We process your personal data for marketing purposes in accordance with applicable data protection and privacy laws. You may also choose your preferred communication channels, such as email or postal mail. YOUR RIGHTSYou have the following rights under data protection law: right to access your data, right to rectify inaccurate data, right to erase your data (“right to be forgotten”), right to restrict or object to processing, right to data portability, and right to withdraw consent. You may request correction or deletion of your personal data where applicable. We will respond within the period required by applicable law or within a reasonable timeframe where no statutory period applies for complex requests. These rights can be exercised by contacting us using the details provided in this policy. DATA RETENTIONWe retain your data only as long as necessary for the purposes outlined in this policy. Typically, personal data is retained for up to 6 years unless a longer retention period is required by applicable law after your travel for legal and operational reasons. Marketing data is retained until consent is withdrawn or deemed no longer valid. In certain circumstances, we may retain data longer to comply with legal obligations or defend legal claims. COOKIESOur website uses cookies to enhance user experience and collect analytics. These may include third-party cookies for personalization and site analysis. Cookies are small data files stored on your device that help us understand how you use our website. Disabling cookies may affect your browsing experience. By continuing to use our website, you consent to the use of cookies unless disabled through your browser settings. THIRD PARTY WEBSITESOur website may contain links to third-party websites. We are not responsible for their privacy practices. POLICY UPDATESThis privacy policy may be updated periodically to reflect changes in legislation or internal procedures. We will post the latest version on our website and notify you of significant changes. We encourage you to review this policy regularly to stay informed about how we protect your data. COMPLAINTS PROCEDUREIf you have any questions, concerns, or complaints regarding how we collect, use, or protect your personal data, please contact us using the contact details provided in this Privacy Policy. We will investigate your complaint and respond within a reasonable timeframe. If you are not satisfied with our response, you may seek further remedies or submit a complaint to the competent data protection or regulatory authority in accordance with the applicable laws of your country. CONTACT USIf you have questions or concerns about this policy or your data, please contact: Data Privacy Contact Sportsmedia Indonesia M. Kahfi 2, Jl. Haji Awi Corner No. 47, South Jakarta 12640 - Indonesia Email: info.sportsmedia.ina@gmail.com Phone: +62 812-9898-7319
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