Privacy Policy

Privacy Policy

Draft: 18 July 2021

Effectivedate: 18 July2021

1. Introduction and Application

(a)“Itsmycontact” “us”, “we”, or “our”), is committed to protecting your privacyand the security of your personal information.


(b) Theobjective of this privacy policy (“Privacy Policy”) is to explain how we handleyour personal information. 


(c) Byusing the Service, you agree to the collection and use of personal informationand other information in accordance with this policy. 


(d) ThisPrivacy Policy may change from time to time and it is therefore important youreview it regularly on our Service at


(e) Inthis Privacy Policy the following terms have the following meanings (otherwise,capitalised terms used in this Privacy Policy but not defined have the meaningsgiven to them in the Terms of Service):


User: a Paid Plan User or a Free PlanUser, or a Visitor.


Paid PlanUser: a personwho has signed up to a Paid Plan.


Free PlanUser: a personhow has signed up to a Free Plan.


Visitor: a visitor to the Website (i.e.the Itsmycontact marketing website).


End User:has themeaning give to it in the Terms of Service.


(f) Ifyou are an End User, and want to know how a User handles your personalinformation, please get in touch with the User directly. This Privacy Policy isabout how we collect and use personal information about Users, andVisitors. 

2. What personal information do we collect?

(a)Personal data means information or data about a living individual who can beidentified from that information or data (which includes information or data inour possession or which is likely to come into our possession).

(b) Wecollect several different types of personal information for various purposes.In the table below we have categorised this personal information and describewhat is it and how we may collect it.

(c) Typesof Data Collected:

User data

This isthe personal information that is provided by you (ie a User) when you sign upfor and use the ItsMyContact Service. 

If youhave a Free Plan: Suchpersonal information may include email address, name, username, hashedpassword, city/country when signing up, any country of last sign-in,Language/browser type, vertical (industry), application data (eg userpreference).

If youhave a Paid Plan: Suchpersonal information may include all of the information above, plus creditcard details (stored by Midtrans, not by us), and full name for billingdetails.

Inaddition to theabove, we may use and store information about Visitors. This isanonymised and aggregated in high quantities, and we remove any personalinformation as we are interested in the “how” not the “who”.


Thisincludes information on how the Itsmycontact Service is accessed and used by Users and EndUsers, as well as usernames and passwords, internet protocol (“IP”) addresses(and geographic information from an IP address), browser types, time zonesettings, the time spent on webpages, unique device identifiers and otherdiagnostic data.


We mayuse and store information about your approximate location (e.g. your country,city or postcode) using geographic information from your IP address. We usethis data to provide features of the Itsmycontact Service, and to improve and customisethe Itsmycontact Service. 


Thisincludes your preferences in receiving marketing communications from us.


We usecookies and similar tracking technologies to track the activity on the ItsmycontactService and hold certain information. Cookies are files with small amounts ofdata which may include an anonymous unique identifier. Cookies are sent to yourbrowser from a website and stored on your device. For more information see the“How do we use cookies?” section below.

(d) Certainaspects of your personal information, for example user data, are required forthe Itsmycontact Services and if you fail to supply such information asrequested for specific Itsmycontact Services, we may be unable to provide youwith the products and services in full and your enjoyment of such products andservices may be more limited.

(e)Sensitive data

We do notcollect any sensitive personal information about you (this includes detailsabout your race or ethnic origin, political opinions or associations, religiousbeliefs or affiliations, philosophical beliefs, membership of a professional ortrade association or union, sexual orientation or practices, and criminalrecord information). Nor do we collect any information about your health,genetic background or biometric personal information.

(f)Children’s data

  1. Our services are not intended for use by children under the page of 13 (the “Age Limit”). If you are under the Age Limit, please do not use the Itsmycontact Service and do not provide us your personal information. If you are a parent or guardian and you are aware that an individual (of whom you are a parent or guardian) under the Age Limit has provided us with personal information, please contact us. We will upon notice or discovery take all reasonable efforts to erase or destroy any personal information that may have been collected or stored by us about that individual.
  2. If you are older than the Age Limit but younger than 18 years’ of age (“Provisional Age Bracket”), you must obtain the consent of your parent or guardian to use the Itsmycontact Service before signing up. If you are a parent or guardian and you are aware that an individual (of whom you are the parent or guardian) in the Provisional Age Bracket has provided us with personal information, please contact us. We will, upon notice or discovery, take all reasonable efforts to erase or destroy any personal information that may have been collected or stored by us about that individual.


3. Why do we collect your personal information?

(a) Itsmycontactuses the data we collect for various purposes, including for the most commonpurposes listed below:

  1. To provide and deliver the Itsmycontact Services and to assess, maintain and improve the performance of the Itsmycontact Services.
  2. To  ensure the Service is relevant to you and your device, to notify you about changes to our Service, and to deliver targeted content based on your user data, location and preferences.
  3. For consumer research and to allow you to participate in surveys or interactive features of our Service when you choose to do so.
  4. To provide customer support and to process and respond to a request or complaint that you may have.
  5. To monitor the usage of our Service and to detect, prevent and address technical issues.
  6. To process any of your transactions and to conduct business planning, reporting, and forecasting.
  7. To deliver promotional materials, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
  8. For the administration of our business including for fulfilling and exercising our obligations and rights, exercising or defending legal claims, and managing the relationship with you.
  9. To comply with our legal obligations and law enforcement requests.
  10. To verify your identity and to detect fraud and potential fraud, including fraudulent payments and fraudulent use of the Service.

4. How do we collect your personal information?

(a) Wewill collect personal information directly from you wherever it is reasonableand practical to do so. We may collect personal information from you via:

  1. your use and access of the Itsmycontact Services, including during your registration as a user;
  2. website links, social media or through any other platform or channel where you make personal information available to us;
  3. your response to any surveys or marketing materials we send out;
  4. information and recommendations uploaded to the Itsmycontact Services by yourself or by other users; and
  5. interactions between yourself, other users of the Itsmycontact Services, and our staff.

(b) Wemay also collect your personal information from third parties including:

  1. third parties who partner with us and help us provide our Itsmycontact Services;
  2. third parties that provide us with marketing leads;
  3. third parties for whom we provide marketing and data analysis services; and
  4. via public sources or when you connect with a social network service when using and accessing the Service.

If youprovide us with information about another person (like your employees or targetaudience), you will let that other person know that we use their personalinformation in the ways set out in this Privacy Policy, and that they canaccess the Privacy Policy on the Service or request a copy of it from us.

(c) Thelegal basis for collecting and using personal information will depend on thespecific circumstances in which we collect that data. However we will collectpersonal information from you where:

  1. it is necessary for the performance of a contract to which you are a party (including in connection with the Itsmycontact Services);
  2. you have consented to our use of the personal information for one or more purposes;
  3. the processing is in the legitimate interests pursued by us, and those interests are balanced against your rights to privacy and do not override your interests or fundamental rights to the protection of your personal information; and
  4. to comply with a legal obligation and the law.

5. Who we may disclose your personal informationto?

(a) Thirdparty disclosure

We maydisclose your personal information to various third parties. These thirdparties are likely to include:

  1. technology and media partners in connection with the services that these third parties perform for us;
  2. our lawyers, accountants and professional advisors;
  3. other third party service providers, such as third party branding service providers;
  4. to Itsmycontact related companies;
  5. to law enforcement authorities where we are required to do so by law or as a result of a legal process;
  6. in the event that we sell or transfer all or a portion of our business or assets, to any transferee of such business or assets. Should such a sale or transfer occur, we will use reasonable efforts to require that the transferee uses the personal information that you have provided to us in a manner that is consistent with this Privacy Policy; and
  7. third party payment processors.

(b) Inrelation to 5(a)(7) above, because we provide paid products and/or serviceswithin the Service, we use third party services for payment processing. We willnot store or collect your payment card details. That information is provideddirectly to our third party payment processors whose use of your personalinformation is governed by their privacy policies and their own terms andconditions. These payment processors adhere to the standards set by paymentcard industry data security standards (“PCI-DSS”) as managed by thePayment Card Industry Security Standards Council, which is a joint effort ofbrands like Visa, Mastercard, American Express and Discover. PCI-DSSrequirements help ensure the secure handling of payment information. Thepayment processors we work with are:

  • Midtrans

(c)Disclosure of personal information to other countries

  1. Itsmycontact may transfer personal information to the United States and other countries in which we do business. Itsmycontact may also subcontract certain activities and share your personal information with third parties located outside of Indonesia (which is where we are headquartered).
  2. The countries in which these organisations are located will vary, but, in the course of our business operations, we generally disclose personal information to organisations located in Indonesia, or the United States.. Personal data, therefore, may be subject to privacy laws that are different to those in your country. Such transfers are made in order to provide the Itsmycontact Services and carry out the activities specified in this Privacy Policy. 
  3. We take all steps reasonably necessary to ensure that personal information is treated securely and in accordance with this Privacy Policy and applicable data protection laws, including entering into data transfer agreements where required. No transfer of your personal information will take place to an organisation or a another country unless we believe there to be adequate controls in place including the security of your data and other personal information. For more details please see section 9 (How do we secure your personal information) below.

6. How do we use cookies?

(a) Tohelp improve the service we provide through our Itsmycontact Services, certaininformation is collected from your browser. This information is collected asstatistical information and may include the IP address, browser type, languageand access times. This website also uses cookies to track pages visited andinformation accessed within our website. This information is for statisticalreference, site analysis and to remember your details and preferences when youreturn to that website.

(b) Inmany cases, the tools used on our website record information in a way that doesnot identify you as an individual. In other cases, information may be personalinformation in which case this Privacy Policy will apply.

(c) Belowwe summarise why we use cookies and the different types that we use:

  1. Necessary cookies: are those that are essential to run our website or to enable you to receive a service that you have requested. For example, to operate a Users’ session or any other request type functionality on the Service.
  2. Performance cookies: are those that collect information about how visitors use and interact with our website so that we can improve it. For example, we use Heap Analytics to track anonymous information about how visitors use our Service. This only collects statistical information such as the number of visitors to the Service, how they arrived there (i.e. via a Google search or another website), whether it is a first-time or return visit, etc.
  3. Functionality cookies: are those that remember the choices you make. Without these cookies you may find that certain features are less convenient and reliable. For example, we use these to remember your language and country of choice and to present relevant content or collect statistical information for our User analytics.
  4. Marketing cookies: are those that help us deliver advertising that is more relevant to you and your interests. They include third party cookies placed by our partners and other advertisers who share cookie data with us. For example, we use these cookies to re-target our advertising to appropriate audiences within our advertising partners’ platforms, such as Facebook advertising.

(d) The ItsmycontactService may also use third party website tools from time to time, for exampledata analytics and online survey tools. These third parties have access to yourpersonal information only to perform these tasks on our behalf and areprohibited from disclosing or using it for any other purpose. These serviceproviders may change from time to time, but they generally include thefollowing:

  1. Google Analytics and Google Adwords
  • Google Analytics is a web analytics service offered by Google Inc. that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript programs (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visiting activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms webpage
  • Google AdWords remarketing service is provided by Google Inc. You can control the information Google uses to show you ads here For more information on the privacy practices of Google, please visit the Google Privacy Terms webpage


(e) Yourweb browser can also be configured to reject cookies. If you set up your webbrowser to reject cookies certain functions of the Website may becomeunavailable to you.

7. Direct marketing communications

From timeto time we may send you direct marketing communications regarding our productsolutions and services. We may contact you by electronic messages (e.g. email),online (e.g. through our Service), by mail and by other means, unless youopt-out or we are subject to legal restrictions from doing so. You may opt-outof receiving electronic messages from us at any time by contacting us via thecontact details at the bottom of this Privacy Policy or by using the opt-outmechanism included in our marketing messages.

8. How long do we retain your personal information?

We willretain your personal information for the period necessary to fulfil thepurposes outlined in this Privacy Policy and in each case in accordance withapplicable legal and regulatory requirements in respect of permitted orrequired retention periods and limitation periods relevant to legal action.

9. How do we secure your personal information?

(a) Wehave put in place appropriate security measures to prevent your personalinformation from being accidentally lost, used or accessed in an unauthorisedway, altered or disclosed.

(b) Inaddition we limit access to your personal information to employees, agents,contractors and other third parties who have a business need for access. Theywill only process your personal information on our instructions and they aresubject to a duty of confidentiality.

(c) Whilewe strive to use commercially acceptable means to protect your PersonalInformation, we cannot guarantee its absolute security. Therefore we have putin place procedures to deal with any suspected personal information breach andwill notify you and any applicable regulator of a breach where we are legallyrequired to do so.

10. Links to other sites

(a) Fromtime to time, our Service (including this Privacy Policy) may contain linksinterfacing with other websites that are not operated by us for yourinformation or convenience. This includes Itsmycontact profiles which arepopulated by the user who built the profile.

(b) Thesewebsites operate independently from our service and may be subject toalternative terms of use, including terms concerning the use of personalinformation. We have not reviewed these third party websites and do not controland are not responsible for how they are operated, their content or privacypolicies.

(c) Ifyou decide to access or interact with any of these third party websites, you doso at your own risk. As such, we strongly encourage you to review the privacypolicy of every website you visit.

11. What are your rights in relation to personalinformation?

(a)Access and correction of personal information

  1. We take reasonable steps to ensure that the personal information we handle is accurate, complete and up-to-date. If you become aware of any errors in your personal information or, if you change your personal information, please let us know.
  2. You can request access to any personal information we hold about you at any time. From time to time, we may need to reject your request to access personal information we hold about you, if we believe it to be necessary and to the extent allowed by law. To request access to any personal information that we may hold about you, please contact us using the contact details at the bottom of this Privacy Policy. Depending on your request and where permitted by law, we may charge a small fee for complying with your request.
  3. You may also request us to amend any personal information we hold about you which you believe to be inaccurate, incomplete or out of date. To request an amendment to any personal information that we hold about you, please contact us using the contact details at the bottom of this Privacy Policy. If we do not agree to amend your personal information, you may request that we make a note of your requested correction with the information we hold about you.
  4. If we are unable to, or if we are unwilling to provide you with access to any of your personal information, or to correct any of your personal information, we will provide you with our reasons to the extent required by applicable law.
  5. You may also contact us if you wish to obtain further information regarding our privacy practices and the way we handle your personal information.

(b) Otherrights

Subjectto certain limitations and restrictions (e.g. depending on circumstances suchas where you reside) you may have the right to exercise additional rights inrelation to your personal information. This may include the rights under theGeneral Data Protection Regulation (the “GDPR”). Accordingly, the followingrights might be available to you depending on your location and except aslimited under applicable law. These may include the right to:

1.Access, update or to delete the information we have on you

Whenevermade possible, you can access, update or request deletion of your personalinformation directly within your account settings section. If you are unable toperform these actions yourself, please contact us for assistance using thecontact details at the bottom of this Privacy Policy.

2. Theright of rectification

You havethe right to have your information rectified if that information is inaccurateor incomplete.

3. Theright to object

You havethe right to object to our processing of your personal information.

4. Theright of restriction

You havethe right to request that we temporarily or permanently restrict the processingof your personal information.

5. Theright to data portability

You havethe right to be provided with a copy of the information we have on you in astructured, machine-readable and commonly used format.

6. Theright not to be subject to automated decision making

You havethe right to not be subject to a decision based solely on automated decisionmaking, including profiling, where the decision would have a legal effect orproduce a significant effect on you.

7. Theright to withdraw consent

You alsohave the right to withdraw your consent at any time where we relied on yourconsent to process your personal information.

(c) Pleasenote that in order to verify your request or the applicability of any of theseright to your circumstances, we may ask you for further information and toverify your identity before responding to such requests.

(d) Ifyou have any questions about these privacy rights, or how to exercise them,please contact us using the contact details at the bottom of this PrivacyPolicy. You may also have the right to complain to your local data protectionauthority about our collection and use of your personal information.

12. Complaints

(a) Wetake your privacy concerns seriously. If you have a complaint regarding ourhandling of your personal information or concerning our privacy practices, youmay file a complaint with us using the contact details set out at the ContactUs. We will confirm receipt of your complaint and, if we believe necessary, wewill open an investigation into your complaint.

(b) Wemay need to contact you to request further details of your complaint. If aninvestigation has been opened following a complaint made by you, then we willcontact you with the result of that complaint as soon as possible. In theunlikely circumstances we are unable to resolve your complaint to yoursatisfaction, you may contact the local privacy and data protection authoritiesin your jurisdiction.

13. Changes to This Privacy Policy

We mayupdate our Privacy Policy from time to time and it is therefore important youreview it regularly. We will notify you of any changes by posting the newPrivacy Policy on the Service. We will let you know via email and/or aprominent notice on our Service prior to the change becoming effective andupdate the “effective date” at the top of this Privacy Policy. Changes to thisPrivacy Policy are effective when they are posted on this page unless otherwiseset out in the email and/or prominent notice.

14. Contact Us

If youhave any questions about this Privacy Policy, our privacy practices or if youwould like to make a request about any personal information we may hold aboutyou, including correction of

  • By email using [email protected]
  • By visiting this page on our website: 
  • If you want to request any information about how we process, store or use your data or anything relating to personal information and privacy laws, please use our Report Page.

Privacy Policy version

ThisPrivacy Policy v1.0 was last updated on 18 Juli 2021.