INDONESIA
NaviBridge Privacy Policy
Date Last Updated: April 3, 2023
DENSO CORPORATION (the “Company”) respects your privacy. This privacy policy applies
to the use of the NaviBridge mobile application software, all modules downloaded via the
application, including all content, features, functionality, programs, applications, or services
provided in or through the mobile application (collectively, the "NaviBridge") or any services
or functionality provided by the NaviBridge ("Services") and describes our practices and
purposes relating to how personal data collected through the NaviBridge is collected,
retained, processed, utilized, disclosed or transferred.
In order to use the NaviBridge, you must affirmatively consent to be bound by this privacy
policy ("Privacy Policy"), and the use of your personal data as stated herein. If you do not
agree to the terms of this Privacy Policy in its entirety, or have objections to the use of your
personal data as stated herein, you may not access, or otherwise use the site and/or
NaviBridge offerings.
This Privacy Policy does not apply to the practices of entities other than the Company, or
any software, or mobile device applications that the Company does not own or control, with
whom you may interact while using the NaviBridge.
1. Personal Data to Be collected and Processed
All personally identifiable information i.e. any information relating to a person, whether true
or not, which, either directly or indirectly, in combination with other information, is capable
of identifying such person (“Personal Data”) is collected by NaviBridge and stored on
DENSO's servers in Japan , and is neither collected nor disclosed to the Company by a
third party with your consent.
The Company shall collect and process (meaning any operation or set of operations which
is performed upon Personal Data or sets of Personal Data, whether or not by automated
means, and such operation means acquisition, recording, organization, structuring, storage,
rectification, alteration, recovery, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment, combination, restriction, erasure or
destruction; hereinafter the same) the Personal Data of the user that you give us through
the Service, including but not limited to the following information.
* User ID
* Nickname or short name that you provide
* Location information of user (including during background operation)
* Location information you register with the App (e.g., favorite places),
* Use log of the NaviCon and NaviBridge (including location and time of use),
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* History of access to Companys server (including time, IP address and Cookie).
Since it is necessary for the Company to receive such information from the user to provide
the user with the service, the user who cannot provide such information may not use the
Service.
2. Legal Basis for Collecting and Purpose of Processing Personal Data
We will process your personal data on the following legal bases unless such data
processing would conflict with applicable laws and regulations:
- Contract. When we need to process your personal data to perform a contract we
enter into with you.
- Legal Obligation. When we need to comply with a legal obligation.
- Legitimate Interests. When the processing of your personal data is necessary
for the fulfilment of legitimate interests pursued by us or a third party and your
interests and fundamental rights do not override those interests.
- Consent. When you have given consent for us to process your personal data.
However, even if we obtain consent from you, we may process your personal data
based on other legal grounds. The withdrawal of your consent shall not affect the
lawfulness of processing performed based on the consent before your withdrawal.
We use the personal data that we hold about you for the following purposes. We will
only use your personal data to the extent that it is necessary to do so to fulfil the
purposes described below.
- To provide merchandise or Services that you request (based on contract or
legitimate interests)
- To improve our merchandise or Services we provide to you (based on contract or
legitimate interests)
- To provide information and communications; to conduct questionnaires relating to
products, services, various events, campaigns, and similar matters (based on
legitimate interests)
- To conduct sales analysis, investigations, and research; to develop new services
and products (based on legitimate interests)
- To conduct web analytics (see our Cookie Policy)
- To ensure compliance with legal obligations (such as record keeping obligations),
export control and customs, compliance screening obligations (to prevent white-
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collar or money laundering crimes), and our policies or industry standards (based
on legal obligation or legitimate interests)
- To solve disputes, enforce our contractual agreements and to establish, exercise
or defend legal claims (based on legal obligation or legitimate interests).
You may experience disadvantages if you refuse to provide your personal data, such
as being unable to make use of some of our services.
The Company shall keep the Personal Data of the user as long as it is necessary to provide
the user with the service but promptly erase it if it is no longer necessary.
3. Provision to Third Party
For the purposes set out in this Privacy Policy, the Company may disclose your Personal
Data to third parties data processer, (e.g., personal information processor) so that they
can perform their role. Third parties shall be subject to contractual obligations to
implement appropriate technical and organizational measures to safeguard and process
your personal information as instructed.
Meanwhile, the Company may disclose your personal information, when duly required
by law, to third parties such as government authorities, courts, or external advisors.
4. Ensuring of Accuracy
The Company shall endeavor to keep the Personal Data up to date and if it is inaccurate or
insufficient, rectify it.
5. Security
To prevent unauthorized access to Personal Data or divulgence of Personal Data, the
Company evaluates and determines the risk of breach of the Personal Data privacy in a
comprehensive manner after taking into account the category of Personal Data, degree of
sensitivity, influence including economic and mental damage to the user when the Personal
Data privacy is breached, and takes personnel, organizational and technical safety
management measures that are necessary and appropriate according to the risk of breach
of Personal Data privacy, set the process to inspect and correct such safety management
measures as necessary and makes ceaseless efforts to improve security.
Since we do not collect your Personal Data other than information stored by the NaviBridge
on your mobile device, it is your responsibility to ensure that you prevent unauthorized
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access, loss or theft of the personal data on your mobile device by the use of security
codes and other access controls. You are solely responsible for maintaining the
confidentiality of your login information and access credentials. Should you choose to not
implement access controls to the NaviBridge, to prevent any unauthorized access to the
NaviBridge or information stored by it, you shall be liable for not enabling and maintaining
appropriate security measures to prevent unauthorized access.
6. Access to Personal Data, Rectification, Erasure, Restriction on Processing, Right
of Data Portability
The user may request the Company make the Personal Data concerning the user retained
by the Company available to the user, rectify or restrict the processing of such information
or take procedures for data portability within the scope which is recognized by the laws and
regulations of each county and region. Further, the user shall have the right to raise an
objection to the Company or data protection authority governing the location where the user
resides with respect to the processing of the Personal Data related to the user within the
scope which is recognized by the laws and regulations of each county and region. If the
user requires the procedures for exercising various types of rights granted to the user with
respect to the Personal Data, please contact us at the following e-mail address.
navicon@jp.denso.com
7. Cross-Border Transfer
The NaviBridge is controlled and operated by us from Japan and is not intended to subject
us to the laws or jurisdiction of any state, country, or territory other than that of Indonesia
with respect to processing of Personal Data that we collect from users in Indonesia. The
information we collect through the NaviBridge may be stored and processed in any country
where we have facilities, or in which we engage service providers, and by using the
NaviBridge, you consent to the transfer of information to countries outside of your country
of residence, which may have different data protection rules than those of your country. In
the event of us transferring any of your Personal Data to countries outside of Japan, we will
take steps to ensure that your Personal Data continues to receive a standard of protection
comparable to that provided under, including but not limited to, Minister of Communication
and Informatics Regulation No. 20 of 2016 on Personal Data Protection in Electronic
Systems.
8. Amendment to Privacy Policy
From time to time, we may amend this Privacy Policy. Any changes will become effective
when we post the revised Privacy Policy in the NaviBridge. We will provide you notice by
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notification that is displayed on your mobile device when NaviBridge is launched for the first
time after the change is made to the Privacy Policy, as appropriate, and update the “Last
Updated” date at the top of this Privacy Policy. If there any material updates, we will require
you to consent or sign up to such modified terms by way of in an pop-up before continuing
to use the NaviBridge and also send push notification via the NaviBridge (unless you have
turned such functionality off). You are encouraged to review this Privacy Policy from time to
time.
9. Company’s Policy for Children
If you are less than 21 years of age, you will need your parent's or legal guardian's
permission to use the NaviBridge, and you may only access or use the NaviBridge under
the supervision of a parent or legal guardian who has consented to and agreed to be bound
by this Privacy Policy. We encourage parents or legal guardians with queries or concerns to
contact us at: navicon@jp.denso.com.
10. Inquiries
If the user has any matter for consultation or question with respect to the privacy policy or
the processing of the Personal Data by the Company, or request with respect to the access
to, rectification or erasure of the Personal Data, restriction on processing or right of data
portability, please contact the Company at the following email address.
navicon@jp.denso.com
11. Language
This Privacy Policy is made in both the English language and the Indonesian language.
Both texts are equally original. In case of any inconsistency or different interpretation
between the English text and the Indonesian text, the relevant Indonesian text shall be
deemed to be automatically amended to conform with and to make it consistent with the
relevant English text.
12. Administrator and Representative
If you have any questions, complaints, or requests regarding the processing of your
personal data, this Privacy Policy, or your rights, please contact us at:
DENSO CORPORATION
1-1, Showa-cho, Kariya, Aichi, Japan
navicon@jp.denso.com