Privacy Policy

Effective Date: September 15th 2025

Last Updated: September 15th 2025

1. Introduction

GabaG AplikASI (“we,” “us,” “our,” or the “Company”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our mobile application (“App”) in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

By using our App, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of information in accordance with this policy.

2. Data Controller Information

Data Controller: PT. GABAG Indonesia Address: Green Lake City, Rukan crown Blok i No 05, RT 012/RW 011, Kel. Petir, Kec. Cipondoh, Kota Tangerang, Banten 15147, Indonesia Email: info@gabag-indonesia.com Phone: +62 811-8242-224

3. Information We Collect

3.1 Personal Data

We may collect the following categories of personal data:

• Account Information: Name, email address, phone number, username, and password
• Profile Information: Profile picture, preferences, settings
• Communication Data: Messages, support requests, feedback
• Transaction Data: Purchase history, payment information (processed by third-party payment providers)

3.2 Technical Data

• Device information (device type, operating system, unique device identifiers)
• App usage data (features used, time spent, crash reports)
• Network information (IP address, connection type)
• Location data (if explicitly permitted by user)

3.3 Cookies and Similar Technologies

We use cookies, pixel tags, and similar technologies to enhance user experience and analyze app performance. You can manage cookie preferences through your device settings.

4. Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR:

• Consent: When you provide explicit consent for specific processing activities
• Contract: To perform our contractual obligations when you use our services
• Legitimate Interest: To improve our services, ensure security, and conduct analytics
• Legal Obligation: To comply with applicable laws and regulations

5. How We Use Your Information

We use your personal data for the following purposes:

• Providing and maintaining the App functionality
• Creating and managing user accounts
• Processing transactions and providing customer support
• Sending important notifications and updates
• Improving App performance and user experience
• Conducting security monitoring and fraud prevention
• Complying with legal obligations and enforcing our terms

6. Data Sharing and Disclosure

6.1 Third-Party Service Providers

We may share your data with trusted third-party providers who assist us in:

• Cloud hosting and data storage
• Payment processing
• Analytics and performance monitoring
• Customer support services
• Marketing and communications

6.2 Legal Requirements

We may disclose your information when required by law, court order, or government regulation, or to protect our rights, property, or safety.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the new entity.

7. International Data Transfers

If you are located in the European Economic Area (EEA), your data may be transferred to and processed in countries outside the EEA. We ensure adequate protection through:

• EU Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• Other appropriate safeguards as required by GDPR

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy:

• Account Data: Until account deletion or 3 years of inactivity
• Transaction Records: 7 years for tax and legal compliance
• Technical Logs: 12 months for security and performance analysis
• Marketing Communications: Until you unsubscribe or withdraw consent

9. Your Rights Under GDPR

If you are located in the EEA, you have the following rights:

9.1 Access Right

Request a copy of the personal data we hold about you.

9.2 Rectification Right

Request correction of inaccurate or incomplete personal data.

9.3 Erasure Right (“Right to be Forgotten”)

Request deletion of your personal data under certain circumstances.

9.4 Restriction Right

Request limitation of processing your personal data.

9.5 Portability Right

Request transfer of your data to another service provider in a structured format.

9.6 Objection Right

Object to processing of your personal data for direct marketing or legitimate interests.

9.7 Withdrawal of Consent

Withdraw consent for processing activities based on consent.

To exercise these rights, contact us at: info@gabag-indonesia.com

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication mechanisms
• Staff training on data protection practices
• Incident response procedures

11. Children’s Privacy

Our App is not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware of such collection, we will delete the information immediately.

12. Automated Decision-Making

We may use automated processing for:

• Fraud detection and security purposes
• Personalized content recommendations
• Analytics and performance optimization

You have the right to request human review of automated decisions that significantly affect you.

13. Data Breach Notification

In the event of a personal data breach that poses a high risk to your rights and freedoms, we will notify you without undue delay and within 72 hours of becoming aware of the breach.

14. Updates to This Policy

We may update this Privacy Policy periodically. We will notify you of significant changes through:

• In-app notifications
• Email notifications (if you have provided an email address)
• Updates posted on our website

15. Supervisory Authority

If you are located in the EEA and believe we have not addressed your privacy concerns adequately, you have the right to lodge a complaint with your local data protection supervisory authority.

16. Contact Information

For any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

Privacy Contact: Email: info@gabag-indonesia.com Address: Green Lake City, Rukan crown Blok i No 05, RT 012/RW 011, Kel. Petir, Kec. Cipondoh, Kota Tangerang, Banten 15147, Indonesia Phone: +62 811-8242-224