Introduction

This policy together with our Terms of Use applies to your use of:

• LOKET mobile application software (App), once you have dowloaded or streamed a copy of the App onto your mobile device.
• LOKET website, https://www.loket.app (Information Site)
• Any of the services accessible through the App (Services) that are available on the App or other websites of ours like the Information Site

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

The App is not intended for children or minors and we will not knowingly collect data relating to children or minors.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important Information and Who We Are

LOKET is the brand name of our App and the Information Site which is owned by our registered company Damowa Golden River Holdings Inc., collectively referred to as the “Company” , “we”, “us”, or “our” in this policy. The Company is the controller for your personal data and we have appointed a data protection representative. If you have any questions about this Privacy Policy, please contact then through the designated email address: [email protected]

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our Privacy Policy under regular review. This version was last updated in June 26, 2021 and it may be changed and updated from time to time. If it odes, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you. In any case, if you have not specifically instructed otherwise, you are deemed to have given your consent for us to process, store and, if needed, share your data and private information and all other data pursuant to this Privacy Policy, from the time you used our Services or App.

Third Party Links

The App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services. We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data
• Contact data
• Transaction Data
• Device Data
• Content Data
• Profile Data
• Usage Data
• Marketing and Communications Data
• Location Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We will only process Special Categories or Personal Data about you if you voluntarily place such information in the course of using the App (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation and political opinions). We do not collect any information about criminal convictions and offecnes.

How Is Your Personal Data Collected?

We will collect and process the following data about you:

• Information you give us. All information provided to us by you(including Identity, Contact, Financial, and Marketing and Communications Data) are deemed that you have given your consent to giving us about you by filling in forms on the App Site or Service Sites (together our Sites) or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, you download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions, enter a competition, promotion or survey, and/or when you report a problem with the App, our Services, or any of our Sites. If you contact us, we will keep a record of that correspondence to which you give your consent to us keeping that record.
• Information we collect about you and your device. Each time you use the App or access our Sites we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy below for further details.
• Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings. We will not pass your Location Data onto a third party (including those External Third Parties identified in the Glossary below) unless it is strictly necessary to provide the Services to you or to comply with a legal obligation imposed on Us.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below
• Device Data from analytics providers such as Google Analytics based outside the Philippines;
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Data Collect based inside the Philippines
• Identity and Contact Data from Google accessing your Google login data;
• Identity and Contact Data from Facebook accessing your Facebook login data
• Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, the Information Site and the distribution platform (App Store or Google Play) and to remember your preferences. This helps us to provide you with a good experience when you use the App or when you use any of Our Sites and also allows us to improve the App and our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy below.

How We Use Your Personal Data

• We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• See below to find out more about the types of lawful basis that we will rely on to process your personal data. We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

 

Purpose/activity	Type of data	Lawful basis for processing
To install the App and register you as a new App user	Identity Contact Financial Device	Your consent Performance of a contract with you
To process in-App purchases and deliver Services including managing payments and collecting money owed to us	Identity Contact Financial Transaction Device Marketing and Communications Location	Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services	Identity Contact Financial Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey	Identity Contact Device Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to analyze how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing	Identity Contact Device	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyze the effectiveness of the advertising we serve you To monitor trends so we can improve the App	Identity Contact Device Content Profile Usage Marketing and Communications Location	Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)
To enable you to use the Services	Content (Special Category)	Consent and Explicit Consent (Article 9 (2)(a)) Processing relates to personal data which has been made manifestly public by the data subject (Article (2) (e)

 

Disclosures of your Personal Data

When you provide us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

In the absence of any instruction to the contrary, you are deemed to have given your consent to the disclosures of your personal data from the time you used our Services.

Data Security

All information you provide to us is stored on secure servers operated on Cloud by Amazon Web Services (AWS). Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using SSL. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way. We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5 and other technology. Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data Retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. We will only retain Location Data for a maximum period of six months. In some circumstances you can ask us to delete your data: see Your legal rights below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

• Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer or your personal data.
• Right to withdraw consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes. You can exercise any of these rights at any time by contacting us at [email protected]

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or when clicking acceptance of the terms of use of this App. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

 

Service providers acting as processors based in the Philippines and Singapore who provide IT and system administration services. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Singapore and Philippines who provide consultancy, banking, legal, insurance and accounting services. Regulators and other authorities acting as processors or joint controllers based in the Philippines and Singapore who may require reporting of processing activities in certain circumstances. Service providers acting as processors based in the United States such as Google Analytics and other third party companies to provide website and App analytics and analysis.

Description of Categories of Personal Data

• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, passport number, educational or professional background, job title or function
• Contact Data: billing address, delivery address, email address and mobile telephone numbers.
• Financial Data: bank account and payment card details and any other data necessary for processing payments and fraud prevention including security code numbers and related billing information
• Transaction Data: includes details about payments to and from you and details of in-App purchases.
• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, browser plug-in types and versions, operating systems and platform.
• Content Data: includes information stored on your Device, including contact lists, login information, photos, videos or other digital content
• Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preference.
• Location Data: includes your current location disclosed by GPS technology. We will use this data only for the purpose of authenticating your location when you select a particular market to enter.
• Sensitive personal data: In the event you voluntarily or accidently reveal sensitive information about you (that is your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sex life or sexual orientation, details or criminal offences or genetic or biometric data.
• Description of categories of personal data
• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, passport number, educational or professional background, job title or function
• Contact Data: billing address, delivery address, email address and mobile telephone numbers.
• Financial Data: bank account and payment card details and any other data necessary for processing payments and fraud prevention including security code numbers and related billing information
• Transaction Data: includes details about payments to and from you and details of in-App purchases.
• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, browser plug-in types and versions, operating systems and platform.
• Content Data: includes information stored on your Device, including contact lists, login information, photos, videos or other digital content
• Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preference.
• Location Data: includes your current location disclosed by GPS technology. We will use this data only for the purpose of authenticating your location when you select a particular market to enter.
• Sensitive personal data: In the event you voluntarily or accidently reveal sensitive information about you (that is your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sex life or sexual orientation, details or criminal offences or genetic or biometric data.

Cookie Policy

What are cookies?

Cookies are very small text files that the server used to operate the website sends to the user’s web browser. They are saved on your computer or mobile device. When you visit the website or App, the server reads the contents of the cookies saved in your device.

 

What are cookies for?

 

Loket uses cookies that save and frequently retrieve the user’s information in order to:

• Recognise you when you re-visit Our Sites. This helps us to personalise our content and information such as optimised advertisements. It also enables us to recognise your preferences each time you visit.
• Recognise how many visitors to Our Sites and visitor behaviour. This helps us to improve our services and functionality. We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.