Kebijakan Privasi Perlindungan Data dan Informasi Pribadi

1. Introduction

In this Privacy Policy, the following terms have the meanings below:
"ESB" or "We" means PT Esensi Solusi Buana and its affiliates as the owner, manager, and operator of the ESB Websites and ESB Applications;
"ESB Application" or collectively "ESB Applications" means applications owned, managed, and controlled by ESB and that relate to the ESB Websites;
"ESB Platform" or collectively "ESB Platforms" means platforms owned, managed, controlled, or used by ESB;
"ESB Service" or collectively "ESB Services" means services provided and managed by, and under the control of ESB, available in the ESB Applications, ESB Websites, or ESB Platforms;
"ESB Website" or collectively "ESB Websites" means https://www.esb.id, related sites and microsites accessed through https://www.esb.id, and the sites owned, managed, and controlled by ESB;
"Personal Data" has the meaning described in Section 2.2;
"Privacy Policy" means the terms and conditions on this page, and the agreements, relating to Personal Data and applicable to each and all ESB Websites, ESB Applications, ESB Services, and ESB Platforms;
"Merchant" means an individual or business entity, including its authorized representative, that has registered and/or executed an agreement with ESB to use the ESB Services in its business operations;
"User" or "You" means any person, business entity, or authorized representative of a business entity, who visits, accesses, and/or uses the ESB Applications, ESB Website, ESB Services, or ESB Platforms or holds or registers an account in the ESB Applications, ESB Website, ESB Services, or ESB Platforms as a Merchant, a Merchant's employee, an End User, a visitor to ESB's site/application, or our business partner;
"End User" means an individual who uses or accesses the ESB Applications, ESB Website, ESB Services, or ESB Platforms developed and/or operated by ESB, or an individual who uses services from a Merchant and whose data are processed by ESB for the purpose of providing ESB Services to that Merchant.

This Privacy Policy is prepared as our expression of compliance with laws and regulations relating to the protection of personal data and information, and as our concrete commitment to protect each User's Personal Data.

ESB is not responsible for: (i) any action, consequence, or matter, including without limitation those relating to Personal Data, contained in or provided on any site, application, or platform that is not operated by ESB; (ii) links to other internet sites or content owned or operated by any party other than ESB; or (iii) sites, applications, platforms, or content that are not operated by or under ESB's control. ESB is not responsible for errors, omissions, delays, defamation, libel, falsehoods, pornography, obscene content, inaccuracies or other material contained in such content, or the consequences of accessing such sites, applications, or platforms.

We recognize the importance of the Personal Data entrusted to us and it is our responsibility to collect, store, protect, process, analyze, and manage such Personal Data to the best of our ability in accordance with applicable laws and for the benefit of the owners of the Personal Data.

By visiting, accessing and/or using any of the ESB Websites, ESB Applications, ESB Services, or ESB Platforms; or by visiting, registering and/or creating an account in any of the ESB Websites, ESB Applications, ESB Services, or ESB Platforms, you acknowledge, declare, and consent (which acknowledgment, declaration, and consent are given knowingly, without coercion or influence from any party, including ESB, and without any form of coercion or influence from anyone or anywhere) that you are required to and have read and fully understood, accepted, agreed to, and are legally bound by each and all terms and conditions in this Privacy Policy, including without limitation the practices applied by ESB in relation to Personal Data, and therefore you agree and permit (such consent and permission being given knowingly, without coercion or influence from any party including ESB, and without any form of coercion or influence from anyone or anywhere) ESB to collect, store, process, disclose, analyze, and/or manage your Personal Data as set out and described in this Privacy Policy.

You understand and agree that ESB, upon giving notice to you, has the right to amend this Privacy Policy at any time in accordance with the provisions in the section on Changes, Additions, and Updates to the Privacy Policy. This Privacy Policy constitutes terms and agreements that are legally binding upon you and ESB, and governs your and ESB's rights and obligations in relation to your Personal Data.

By using the ESB Applications, ESB Website, ESB Services, or ESB Platforms, you agree that your consent covers all data processing activities carried out by ESB in accordance with this Privacy Policy, including the collection, use, disclosure, and transfer of data to partners and third parties for the purposes stated in this policy, insofar as conducted in compliance with applicable law.

IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, OR DO NOT AGREE WITH THE PRACTICES APPLIED BY ESB IN RELATION TO PERSONAL DATA, OR DO NOT PERMIT THE COLLECTION, STORAGE, PROCESSING, DISCLOSURE, ANALYSIS, OR MANAGEMENT OF YOUR PERSONAL DATA AS SET OUT AND DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT VISIT, ACCESS, USE, REGISTER, OR CREATE AN ACCOUNT ON ANY ESB WEBSITE, ESB APPLICATION, ESB SERVICE, OR ESB PLATFORM.

Effective as of August 14, 2025

2. Collection and Storage of Personal Data

2.1.	The times or circumstances in which ESB may obtain, collect, and/or store your Personal Data include but are not limited to the following:

	(a)	You visit, access and/or use any of the ESB Websites, ESB Applications, ESB Services, or ESB Platforms;
	(b)	You visit, register and/or create an account in any of the ESB Websites, ESB Applications, ESB Services, or ESB Platforms;
	(c)	You submit any form or application in connection with the ESB Websites, ESB Applications, ESB Services, or ESB Platforms;
	(d)	You enter into an agreement, interact, or correspond in any form, whether in writing or otherwise, through any medium including but not limited to the ESB Website, ESB Applications, ESB Services, or ESB Platforms, with us, in connection with or on any of the ESB Websites, ESB Applications, ESB Services, or ESB Platforms, or an account in the ESB Websites, ESB Applications, ESB Services, or ESB Platforms;
	(e)	You grant your device permission to share information with the ESB Website, ESB Applications, ESB Services, or ESB Platforms;
	(f)	You link the ESB Website, ESB Applications, ESB Services, or ESB Platforms, or an account in the ESB Website, ESB Applications, ESB Services, or ESB Platforms, to social media or other external accounts or when you use social media features or other online platforms in accordance with the provider's policy;
	(g)	You submit any Personal Data to ESB for any reason and by any means;
	(h)	You interact with other Users or upload comments, discussions, messages, reviews, or ratings on any matter through the ESB Website, ESB Applications, ESB Services, or ESB Platforms; or
	(i)	You register for an event organized by ESB or another party that uses ESB, or at an event where ESB is a sponsor, supporter, or organizer.

2.2.

ESB may collect, store, use, disclose, analyze, and/or manage any data, information, content, or other similar matters, identified and/or identifiable on its own or in combination with other information, whether directly or indirectly through electronic and/or non-electronic systems, including but not limited to (“Personal Data”):

	(a)	basic user information such as full name, details of business legality documents, email address, residential and permanent address, phone number, date of birth, age, bank account details, employment information, credit card and/or financial account information;
	(b)	information and content in your account registered on the ESB Website, ESB Applications, ESB Services, or ESB Platforms;
	(c)	any information uploaded by you or any information about your products and services;
	(d)	information inherent to you when you access or use the ESB Website, ESB Applications, ESB Services, or ESB Platforms, including but not limited to real or approximate location data such as IP address, Wi‑Fi location, and geo‑location, unique ID, referrer URL, browser type and settings, mobile network information, information about your application, browser, and device interactions;
	(e)	any information on the computer, phone, or other device from which you access, upload, or use the ESB Website, ESB Applications, ESB Services, or ESB Platforms, depending on the permissions you grant;
	(f)	any information collected by cookies, web beacons, and general log information;
	(g)	technical and usage behavior information from analytics software (including but not limited to cookies, pixel tags, and beacons) used by ESB or its partners for analytics, product development, and personalized marketing purposes;
	(h)	ESB may combine the foregoing data and information obtained with data or information already held by ESB.

2.3.	You agree and permit (such consent and permission being given knowingly, without coercion or influence from any party including ESB, and without any form of coercion or influence from anyone or anywhere) that:

	(a)	You will not submit any part of Personal Data or any information that is inaccurate or misleading, including without limitation using Personal Data or information belonging to other persons or any third party (including other Users) without the consent of the owner of such Personal Data or information; and in the event of any claim, demand, lawsuit, or loss arising from a breach of this provision, you hereby agree and warrant to be fully responsible for such claim, demand, lawsuit, or loss, whether civil or criminal;
	(b)	If you have not reached the age of majority under applicable laws, you are not permitted to use the ESB Websites, ESB Applications, ESB Services, or ESB Platforms without the consent of a parent or legal guardian. Where you disclose a minor’s Personal Data to us, you hereby represent and warrant that the collection, use, and processing of such Personal Data have been conducted with valid consent from the parent or authorized guardian. Furthermore, the parent or legal guardian is deemed to have read, understood, and agreed to this Privacy Policy and to the terms herein;
	(c)	ESB is entitled, from time to time, to verify the Personal Data you provide to us by sending a verification letter or email, requiring you to submit supporting documentation, or by other means as requested; and
	(d)	Your Personal Data may be disclosed to the following parties: (a) ESB’s affiliates and subsidiaries, agents, and subcontractors; (b) governmental authorities, regulators, and fraud prevention agencies for the purposes of identifying, preventing, detecting, or addressing fraud, money laundering, or other crimes, and for other legitimate purposes; (c) third parties for risk management, the conduct of internal and external audits, including information technology audits and legal compliance, to ensure system integrity and compliance with laws and ESB’s internal policies; (d) other entities as may be required by law or as the public interest may require for the purposes described in the following paragraph; and (e) a purchaser in the event of an acquisition. You hereby acknowledge, understand, declare, and agree (such acknowledgment, understanding, declaration, and agreement being given knowingly, without coercion or influence from any party including ESB, and without any form of coercion or influence from anyone or anywhere, and which you will not revoke or withdraw for any reason) that such disclosure must be made and you agree to waive your right to claim damages to the extent permitted by law. Except as set forth herein, we will not disclose your Personal Data to any party without your specific consent.
	(e)	For the purposes of service and feature development, quality improvement, and internal and external data processing, you agree that Personal Data may be processed and/or shared with third-party service providers (including but not limited to providers of technology, analytics, payment processing, telecommunications, and marketing services), whether located within or outside the jurisdiction of the Republic of Indonesia, insofar as in accordance with applicable laws and regulations.

2.4.	To the extent permitted by applicable laws and regulations, your Personal Data will be retained by ESB for the period necessary to fulfill the purposes set out in this Privacy Policy.

3. Use and Management of Personal Data

3.1.

ESB uses Personal Data to, among others, provide services to you as a user, maintain, and improve the ESB Website, ESB Application, ESB Services, and ESB Platforms (including personalizing product data such as product recommendations, food recommendations, and other analyses according to your persona), and to deliver information and support you request, including receipts, alerts, support, and administrative advertising messages.

3.2.

You agree and permit (such consent and permission being given knowingly, without coercion or influence from any party including ESB, and without any form of coercion or influence from anyone or anywhere) that ESB may use your Personal Data obtained and collected in accordance with this Privacy Policy for activities that support our purposes as mentioned above, including but not limited to:

	(a)	processing any form of requests, activities, and transactions conducted by Users through the ESB Website, ESB Applications, ESB Services, and/or ESB Platforms;
	(b)	sending news and information regarding the ESB Website, ESB Applications, ESB Services, and/or ESB Platforms, including but not limited to products, services, promotions and/or updates offered by ESB or ESB’s partners, insofar as permitted by you. If you choose not to receive such news and information, we are not responsible for any loss or consequences that you may experience as a result of not being aware of such news and information, which may include prize draws, competitions, contests, challenges, rewards, bonuses, promotions, or similar matters;
	(c)	improving the ESB Websites, ESB Applications, ESB Services, and ESB Platforms to better support Users’ needs, desires, and interests;
	(d)	reviewing and resolving User issues;
	(e)	contacting and/or communicating with you, and responding to your questions and comments;
	(f)	conducting research, analysis, development, testing, and marketing of the ESB Websites, ESB Applications, ESB Services, ESB Platforms, and other ESB products, and developing new features and products;
	(g)	enabling audits and surveys for the improvement and development of the ESB Websites, ESB Applications, ESB Services, ESB Platforms, and other ESB products, including validating audience size and composition, conducting market research, and understanding experiences and feedback on access to and use of the ESB Websites, ESB Applications, ESB Services, ESB Platforms, and other ESB products;
	(h)	archiving, data storage, statistics, and research for internal reporting purposes and those required by laws and regulations, as well as maintaining and preserving backups of your Personal Data;
	(i)	responding to any claim or lawsuit filed or that may be filed;
	(j)	monitoring or investigating suspicious uses, transactions, or actions or those indicated to contain elements of fraud or violations of: (i) this Privacy Policy; (ii) the terms and conditions and policies for using and accessing the ESB Website, ESB Applications, ESB Services, ESB Platforms, and/or other ESB products; and (iii) applicable laws and regulations, and taking follow-up actions based on the results of such monitoring and investigation;
	(k)	in certain circumstances, for law enforcement purposes or to meet legal requirements and obligations under applicable laws and regulations, including in the event of disputes or legal proceedings, whether criminal or civil, involving the User and/or ESB;
	(l)	facilitating corporate or business transactions including but not limited to mergers, sales of company assets, consolidations or restructurings, financing or acquisitions involving ESB, the ESB Websites, ESB Applications, ESB Services, or ESB Platforms;
	(m)	protecting ESB’s legitimate interests, including but not limited to carrying out internal operational purposes such as data analysis, service quality assurance, insurance, information technology and network security, and risk and credit management;
	(n)	delivering promotions, offers, or marketing communications from third parties cooperating with ESB, including commercial partners, technology providers, or event organizers;
	(o)	delivering personalized offers to you based on usage preferences, whether by ESB or by verified partners, with data protection safeguards in accordance with ESB standards; and/or
	(p)	any other purpose that we notify you of at the time we obtain your consent.

3.3.	For the avoidance of doubt, where personal data regulations or other applicable laws permit an organization such as ESB to collect, use, or disclose your Personal Data without your consent, the permission granted by such laws shall continue to apply.

4. Storage and Security of Personal Data

4.1.

You hereby acknowledge and understand that, although we strive to protect your Personal Data, we cannot guarantee the integrity and accuracy of Personal Data you submit via the internet as the transmission of information over the internet is not completely secure. You are responsible for maintaining the confidentiality of your account details, and you must not share your account details or your information on the ESB Applications, ESB Platforms, ESB Services, and ESB Websites with anyone. You must always safeguard and are responsible for the security of the device you use. You hereby agree to release and hold us harmless from any loss arising directly or indirectly, the risk and/or consequences of Personal Data being accessed, stolen, disclosed, altered or destroyed by unauthorized third parties due to factors beyond our control and/or contrary to this Privacy Policy and Applicable Law, including those caused by your error or negligence.

4.2.

Personal Data transmitted to or stored in the ESB Website, ESB Applications, ESB Services, or ESB Platforms may be accessed by third parties without permission or in an unlawful manner, or the related technology may malfunction or not work as expected, or someone may access, exploit, or misuse the information or Personal Data without fault on the part of ESB. Nevertheless, we will use reasonable security settings to protect your Personal Data as required by applicable laws and regulations; however, inevitably, there is no absolute guarantee of security, including but not limited to unauthorized disclosure arising from sophisticated and malicious hacking by any party without any fault on the part of ESB.

4.3.

ESB implements various safeguards and all measures required by applicable laws and regulations to ensure the security of your Personal Data in the ESB Website, ESB Applications, ESB Services, or ESB Platforms. The acquisition, collection, and storage of your Personal Data are carried out subject to and in accordance with applicable laws and regulations.

4.4.

Your Personal Data may be stored or processed outside the territory of the Republic of Indonesia by parties working with or in relation to ESB in other countries, or by third-party service providers, vendors, suppliers, partners, contractors, or ESB affiliates; in which case ESB will still ensure the security of your Personal Data in accordance with this Privacy Policy and applicable laws and regulations in the Republic of Indonesia.

4.5.

Personal Data of Users under ESB’s control will be deleted and/or anonymized when the Personal Data is no longer needed to fulfill the purposes for which it was collected, and when it is no longer required for compliance with applicable laws and regulations. However, some User Personal Data may be retained by government agencies or state administrators that lawfully receive such Personal Data from ESB for the purpose of fulfilling legal obligations under applicable laws and regulations. In such case, ESB will only disclose Personal Data to parties that are legally authorized under the law. You understand that further retention of such Personal Data will be subject to the data retention policies and internal regulations of the relevant agency.

4.6.

ESB is not responsible for any Personal Data or information you provide or register on sites, applications, services, or platforms of parties other than ESB, including sites, applications, services, or platforms that may be linked within the ESB Website, ESB Application, ESB Services, or ESB Platforms.

5. Your Rights over Personal Data

5.1.

You have the right to know whether your Personal Data is processed by ESB, and to obtain a copy of your Personal Data and information regarding such processing activities. Requests may be submitted by email to [email protected], and ESB will respond within a reasonable time in accordance with applicable laws and regulations. In certain cases, ESB may charge an administrative fee for such requests with prior notice to you.

5.2.

You may correct, update, or complete your Personal Data through your account available on the ESB Website, ESB Applications, ESB Services, and/or ESB Platforms. If this is not possible, you may submit a correction request by email to [email protected], and ESB will process the request according to internal procedures within a reasonable time.

5.3.

You may withdraw your consent to the processing of your Personal Data by submitting a written request to ESB through the official communication channels listed in this Privacy Policy. ESB will process such request in accordance with applicable laws and regulations. You understand that such withdrawal of consent may result in the termination of access to part or all of the ESB Services that depend on the processing of Personal Data, and ESB is not responsible for any consequences arising from such withdrawal.

5.4.

You have the right to request that ESB cease processing, delete, and/or destroy your Personal Data, provided that such request will be processed in accordance with applicable laws and regulations as well as ESB’s internal policies, and provided that you understand and agree that such withdrawal or cancellation of consent means that we will not be able to continue providing you with access to or use of the ESB Website, ESB Applications, ESB Services, and/or ESB Platforms, and any accounts you have created on the ESB Website, ESB Applications, ESB Services, and/or ESB Platforms, and we will not be responsible for any loss or damage that may arise as a consequence of your request to withdraw or cancel your consent. Requests may be submitted through the official communication channels listed in this Privacy Policy.

6. Changes, Additions, and Updates to this Privacy Policy

6.1.

ESB is entitled and may, at any time, make changes, additions, and/or updates to the terms, rules, and content of this Privacy Policy by giving you at least five (5) business days’ notice prior to the effective date, and may modify, update, or amend this Privacy Policy at any time. The latest version of the Privacy Policy will be posted at https://www.esb.id.

6.2.	Each User must carefully read and review this Privacy Policy page from time to time to be aware of changes, additions, and/or updates to it.

6.3.

You hereby understand and agree that by and while you visit, access and/or use any of the ESB Websites, ESB Applications, ESB Services, or ESB Platforms; or visit, register and/or create an account in any of the ESB Websites, ESB Applications, ESB Services, or ESB Platforms, you are deemed to have agreed to each and all terms, rules, and content of this Privacy Policy together with each change, addition, and update to it, and it is binding upon you. Your failure to carefully read and review this Privacy Policy page as required herein does not result in and cannot be used as a reason to argue that the terms, rules, and content of this Privacy Policy together with each change, addition, and update to it do not apply to you.

7. Cross-Border Transfer

Where ESB needs to transfer Personal Data to third parties or service providers outside the territory of the Republic of Indonesia, ESB will ensure that such transfer is carried out in accordance with data protection standards equivalent to or higher than those stipulated under applicable laws and regulations in Indonesia.

8. Consent to Limited Disclosure to Partners

8.1.	By agreeing to this Privacy Policy, you also agree that ESB may share your Personal Data with trusted and verified partners that cooperate with ESB, including but not limited to:

	(a)	technology service providers, system development, and analytics;
	(b)	event organizers and digital marketing service providers;
	(c)	telecommunications service providers; and/or
	(d)	financial institutions and providers of transaction support services; for legitimate purposes such as delivery of OTP codes, system maintenance, measuring the effectiveness of promotions, and service optimization.

8.2.

Each partner is subject to confidentiality and Personal Data protection obligations equivalent to the standards applied by ESB and applicable personal data laws and regulations. This sharing is carried out based on your consent to this Privacy Policy and does not require further separate consent, insofar as it is within the scope and purposes described in this Privacy Policy.

9. Acknowledgment of Prior Processing

You understand that this Privacy Policy applies prospectively as of its effective date and does not apply retroactively to Personal Data processed before that date, unless permitted by applicable law. To the extent your prior Personal Data processing was based on a lawful basis in accordance with the laws and regulations applicable at that time, such processing remains valid and cannot be used as a ground for retroactive objection.

10. Governing Law and Severability

This Privacy Policy is governed by and construed in accordance with the laws of the Republic of Indonesia. If any provision in this Policy is deemed invalid or unenforceable under applicable law, such provision shall not affect the validity of the other provisions, which shall remain in full force and effect.

11. Contact

If you wish to submit questions regarding the processing of your Data or other questions in relation to this Policy, please contact us by email at: [email protected].

Topics

1. Introduction

2. Collection and Storage of Personal Data

3. Use and Management of Personal Data

4. Storage and Security of Personal Data

5. Your Rights over Personal Data

6. Changes, Additions, and Updates to this Privacy Policy

7. Cross-Border Transfer

8. Consent to Limited Disclosure to Partners

9. Acknowledgment of Prior Processing

10. Governing Law and Severability

11. Contact

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Our Privacy Policy

Topics

1. Introduction

2. Collection and Storage of Personal Data

3. Use and Management of Personal Data

4. Storage and Security of Personal Data

5. Your Rights over Personal Data

6. Changes, Additions, and Updates to this Privacy Policy

7. Cross-Border Transfer

8. Consent to Limited Disclosure to Partners

9. Acknowledgment of Prior Processing

10. Governing Law and Severability

11. Contact

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