Kebijakan Privasi

Article 1 — Introduction & Scope

1. Introduction

PT Villa Management Bali ("Kerja Xtra", "we", "our" or "us") is committed to protecting the privacy and personal data of Users who access or use the Kerja Xtra platform.

This Privacy Policy explains how PT Villa Management Bali collects, uses, discloses, stores and otherwise processes your personal data when you use the Kerja Xtra platform, including our mobile application and website.

This Privacy Policy applies to all Users of the Platform, including Clients, Service Providers and visitors who interact with the Platform.

2. Relationship with the Terms & Conditions

This Privacy Policy forms an integral part of the Kerja Xtra Terms & Conditions.

Capitalised terms used in this Privacy Policy have the same meaning as defined in the Terms & Conditions unless otherwise stated.

By accessing or using the Platform, you acknowledge that your personal data may be processed in accordance with this Privacy Policy and the Terms & Conditions.

3. Scope

This Privacy Policy applies to personal data processed by Kerja Xtra through:

• the Kerja Xtra mobile application;
• the Kerja Xtra website;
• communications made through the Platform;
• identity verification processes;
• payment-related processes;
• customer support;
• and any other services, features or functionality that refer to this Privacy Policy.

This Privacy Policy does not apply to personal data processed directly by other Users outside the Platform or by independent third parties that maintain their own privacy policies.

4. Applicable Law

Kerja Xtra processes personal data in accordance with the laws and regulations applicable to the operation of the Platform, including the personal data protection laws of the Republic of Indonesia.

Where the laws of another jurisdiction apply to the processing of personal data, Kerja Xtra will comply with any mandatory legal requirements applicable to that processing.

5. Changes to this Privacy Policy

Kerja Xtra may update this Privacy Policy from time to time to reflect changes in:

• applicable laws or regulatory requirements;
• the Platform or its features;
• our business operations;
• security practices; or
• the way we process personal data.

Where required by Applicable Law, we will notify Users of material changes through appropriate communication channels, such as the Platform, email or other electronic communications associated with the User's Account.

The updated version will indicate the date of its latest revision. Continued use of the Platform after the updated Privacy Policy becomes effective constitutes acceptance of the revised Privacy Policy, to the extent permitted by Applicable Law.

Article 2 — Personal Data We Collect

The categories of personal data that Kerja Xtra collects depend on how you use the Platform, the features you access and the information you choose or are required to provide.

2.1 Information You Provide Directly

When you create or use an Account, publish a Task, submit a Quote, complete Verification, communicate through the Platform or contact us, we may collect personal data including:

• full name;
• email address;
• mobile phone number;
• date of birth, where required;
• residential or business address, where required;
• profile photograph, where you choose to upload one;
• information contained in your profile;
• payment and payout information;
• identity verification documents and related information;
• tax or business information, where required by Applicable Law;
• communications with Kerja Xtra;
• communications with other Users through the Platform;
• reviews, ratings, feedback and other Content you submit; and
• any other information you voluntarily provide through the Platform.

2.2 Task and Transaction Information

When you use the Platform, we may collect information relating to your activities, including:

• Tasks you publish;
• Quotes you submit or receive;
• Contracts formed through the Platform;
• payment transactions;
• Payment Holds;
• Provider Wallet activity;
• Payout requests;
• cancellations;
• Disputes;
• Trust Indicators;
• Verification status;
• customer support requests; and
• other information generated through your use of the Platform.

2.3 Information Collected Automatically

When you access or use the Platform, we may automatically collect certain technical and usage information, including:

• IP address;
• device identifiers;
• device type and operating system;
• browser type;
• application version;
• language preferences;
• approximate location derived from your device or IP address;
• date and time of access;
• log files;
• pages or screens viewed;
• actions performed within the Platform;
• crash reports and diagnostic information; and
• other technical information reasonably necessary to operate, secure and improve the Platform.

Where you expressly permit location access through your device settings, we may collect more precise location information to provide location-based features of the Platform.

2.4 Information Obtained from Third Parties

We may receive personal data from third parties, including:

• identity verification providers;
• payment service providers;
• financial institutions involved in payment processing;
• fraud prevention providers;
• analytics providers;
• communication service providers;
• business partners;
• publicly available sources where permitted by Applicable Law; and
• other service providers supporting the operation of the Platform.

We may combine information obtained from third parties with information collected directly from you where permitted by Applicable Law.

2.5 Information Visible to Other Users

Certain information is intended to be visible to other Users to enable the proper operation of the Platform.

Depending on your use of the Platform, this may include:

• your first name or display name;
• profile photograph;
• Verification status;
• Trust Indicators;
• ratings and reviews;
• number of completed Tasks;
• response metrics;
• information contained in your public profile;
• Task-related information;
• Quotes, where applicable; and
• other information necessary to facilitate interactions between Clients and Service Providers.

Kerja Xtra limits the information displayed to other Users to what is reasonably necessary for the operation, transparency and trust of the Platform.

2.6 Information We Do Not Intentionally Collect

The Platform is not intended to collect categories of personal data that are unnecessary for its operation.

Users should not upload or share sensitive personal data through the Platform unless expressly requested by Kerja Xtra as part of a Verification process or where required by Applicable Law.

If a User voluntarily includes personal data within Task descriptions, messages or other Content, such information may be processed as part of providing the Platform.

Article 3 — How We Collect Personal Data

Kerja Xtra collects personal data through various sources depending on how you interact with the Platform.

3.1 Information You Provide

We collect personal data that you choose or are required to provide when you:

• create or update an Account;
• complete Verification;
• publish a Task;
• submit or accept a Quote;
• make or receive payments;
• request a Payout;
• communicate with other Users through the Platform;
• contact customer support;
• participate in surveys, promotions or feedback requests;
• submit reviews or ratings; or
• otherwise interact with the Platform.

3.2 Information Collected Automatically

Certain personal data and technical information are collected automatically when you access or use the Platform.

This information may be collected through technologies such as application logs, cookies, software development kits (SDKs), device identifiers and similar technologies used to operate, secure, analyse and improve the Platform.

Further information regarding cookies and similar technologies is provided in Article 11 of this Privacy Policy.

3.3 Information from Other Users

Other Users may provide personal data about you in connection with their use of the Platform.

For example, personal data may be collected when another User:

• invites you to use the Platform;
• includes information about you in a Task;
• communicates with you through the Platform;
• submits a review or rating;
• reports a safety concern or Dispute;
• or otherwise interacts with you through the Platform.

3.4 Information from Third Parties

We may receive personal data from trusted third parties supporting the operation of the Platform, including:

• identity verification providers;
• payment service providers;
• fraud prevention providers;
• analytics providers;
• communication service providers;
• business partners;
• publicly available sources where permitted by Applicable Law; and
• other service providers assisting us in operating, securing or improving the Platform.

3.5 Information Generated Through Your Use of the Platform

As you use the Platform, additional information is generated automatically through your activities.

This may include information relating to:

• your Account activity;
• Tasks;
• Quotes;
• Contracts;
• payment activity;
• cancellations;
• Disputes;
• Verification;
• Trust Indicators;
• communications;
• customer support interactions; and
• other Platform activities.

3.6 Information Required by Law

In certain circumstances, Kerja Xtra may collect additional personal data where required to:

• comply with Applicable Law;
• satisfy regulatory obligations;
• verify your identity;
• prevent fraud or financial crime;
• respond to lawful requests from competent authorities; or
• protect the rights, safety and security of the Platform, our Users or third parties.

Where the provision of certain personal data is mandatory under Applicable Law or necessary to provide specific Platform features, your failure to provide that information may prevent us from providing those features or services.

Article 4 — How We Use Personal Data

Kerja Xtra processes personal data only where reasonably necessary to operate the Platform, provide its services, comply with Applicable Law and protect the legitimate interests of the Platform and its Users.

Depending on how you use the Platform, we may process your personal data for the following purposes.

4.1 Providing the Platform

We use personal data to:

• create and manage User Accounts;
• authenticate Users;
• enable Clients and Service Providers to use the Platform;
• publish Tasks and submit Quotes;
• facilitate the formation and administration of Contracts;
• process payments, Payment Holds, Wallets and Payouts;
• provide customer support;
• operate Platform features; and
• otherwise provide the services requested by Users.

4.2 Identity Verification and Trust

We process personal data to:

• complete Verification processes;
• display Trust Indicators;
• improve trust and transparency within the Platform;
• reduce fraud and abuse;
• verify payment or payout information;
• assess eligibility for certain Platform features; and
• protect the integrity of the marketplace.

4.3 Communications

We use personal data to communicate with Users regarding:

• their Account;
• Tasks;
• Quotes;
• payments;
• Payouts;
• cancellations;
• Disputes;
• Verification;
• security alerts;
• updates relating to the Platform; and
• customer support requests.

Where permitted by Applicable Law, we may also send promotional or marketing communications. Users may opt out of such communications at any time where required by law.

4.4 Safety, Security and Fraud Prevention

We process personal data to:

• detect, investigate and prevent fraud;
• identify suspicious activity;
• protect Users and the Platform;
• investigate breaches of the Terms & Conditions or Platform policies;
• prevent abuse of Platform features;
• maintain Platform security;
• respond to safety reports; and
• enforce our contractual and legal rights.

4.5 Payments and Financial Compliance

We process personal data to:

• process payments and refunds;
• administer Payment Holds;
• process Wallet balances and Payouts;
• comply with financial, tax and regulatory obligations;
• prevent payment fraud;
• verify payment information; and
• cooperate with payment service providers where necessary.

4.6 Improving the Platform

We use personal data to:

• analyse how the Platform is used;
• understand User behaviour;
• improve existing features;
• develop new features and services;
• troubleshoot technical issues;
• monitor Platform performance;
• improve the user experience; and
• conduct internal research and analytics.

Where possible, we use aggregated, anonymised or de-identified information for these purposes.

4.7 Legal and Regulatory Compliance

We may process personal data where necessary to:

• comply with Applicable Law;
• comply with court orders or lawful requests from competent authorities;
• respond to regulatory obligations;
• resolve Disputes;
• establish, exercise or defend legal claims;
• enforce the Terms & Conditions and Platform policies; or
• protect the rights, property or safety of Kerja Xtra, our Users or third parties.

4.8 Business Operations

We may process personal data as reasonably necessary to:

• maintain internal records;
• conduct audits;
• manage business administration;
• monitor compliance;
• manage corporate transactions such as mergers, acquisitions or restructurings;
• exercise our legal rights; and
• operate our business efficiently and responsibly.

4.9 Artificial Intelligence and Automated Tools

Kerja Xtra may use automated systems, including artificial intelligence technologies, to support the operation, security and improvement of the Platform.

Such systems may assist with activities including:

• fraud detection;
• identity verification support;
• customer support;
• moderation of Content;
• translation;
• quality assurance;
• analytics; and
• other operational purposes.

Where automated tools are used to support decision-making, Kerja Xtra will implement appropriate safeguards where required by Applicable Law. Automated tools are designed to assist human decision-making and do not replace human oversight where legally or operationally appropriate.

Article 5 — Legal Bases for Processing Personal Data

Kerja Xtra processes personal data only where there is an appropriate legal basis to do so under Applicable Law.

Depending on the circumstances, we may rely on one or more of the following legal bases.

5.1 Performance of a Contract

We process personal data where necessary to:

• create and manage your Account;
• provide access to the Platform;
• publish Tasks;
• submit and manage Quotes;
• facilitate Contracts between Clients and Service Providers;
• process payments, Payment Holds, Wallets and Payouts;
• provide customer support; and
• perform our contractual obligations under the Terms & Conditions.

5.2 Compliance with Legal Obligations

We may process personal data where necessary to comply with Applicable Law, including obligations relating to:

• personal data protection;
• financial regulations;
• taxation;
• anti-fraud measures;
• anti-money laundering requirements, where applicable;
• court orders;
• lawful requests from competent authorities; and
• other legal or regulatory obligations.

5.3 Legitimate Interests

Where permitted by Applicable Law, we may process personal data where necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms.

Our legitimate interests may include:

• operating and improving the Platform;
• protecting Users;
• preventing fraud and abuse;
• maintaining Platform security;
• investigating suspected misconduct;
• improving customer support;
• developing new products and services;
• analysing Platform performance;
• enforcing our legal rights; and
• maintaining the integrity and reliability of the marketplace.

5.4 Consent

In certain circumstances, Kerja Xtra may rely on your consent to process personal data.

This may include, where applicable:

• marketing communications;
• optional location services;
• cookies or similar technologies where consent is required;
• participation in surveys;
• promotional campaigns; or
• other processing activities for which consent is required under Applicable Law.

Where processing is based on your consent, you may withdraw that consent at any time.

The withdrawal of consent does not affect the lawfulness of any processing carried out before the consent was withdrawn.

5.5 Protection of Vital Interests

Where permitted by Applicable Law, Kerja Xtra may process personal data where reasonably necessary to protect the life, health or safety of a User or another individual.

5.6 Other Lawful Grounds

Where Applicable Law permits additional lawful grounds for processing personal data, Kerja Xtra may rely on those grounds where appropriate and necessary.

Article 6 — How We Share Personal Data

Kerja Xtra does not sell personal data.

We share personal data only where reasonably necessary to operate the Platform, provide our services, comply with Applicable Law or protect the rights, safety and security of Kerja Xtra, our Users and third parties.

6.1 Sharing with Other Users

Because Kerja Xtra operates as a marketplace, certain personal data must be shared between Clients and Service Providers to enable the performance of Services.

Depending on the circumstances, this may include:

• your first name or display name;
• profile photograph;
• Verification status;
• Trust Indicators;
• ratings and reviews;
• Task-related information;
• Quotes;
• communications relating to a Task;
• payment status, where relevant;
• and other information reasonably necessary for the performance of the Contract between Users.

Kerja Xtra limits such sharing to information reasonably necessary for the operation of the Platform.

6.2 Service Providers

We may share personal data with trusted third-party service providers that assist us in operating the Platform.

These providers may include, without limitation:

• payment service providers;
• identity verification providers;
• cloud hosting providers;
• communication service providers;
• analytics providers;
• customer support providers;
• fraud prevention providers;
• cybersecurity providers;
• infrastructure providers; and
• other professional service providers supporting our business operations.

These service providers are authorised to process personal data only for the purposes of providing services to Kerja Xtra and in accordance with Applicable Law.

6.3 Legal and Regulatory Disclosures

We may disclose personal data where reasonably necessary to:

• comply with Applicable Law;
• respond to lawful requests from competent authorities;
• comply with court orders or legal processes;
• protect the rights, property or safety of Kerja Xtra, our Users or third parties;
• investigate fraud or unlawful activity;
• enforce the Terms & Conditions or Platform policies; or
• establish, exercise or defend legal claims.

6.4 Business Transactions

If Kerja Xtra is involved in a merger, acquisition, corporate restructuring, investment transaction, financing, sale of assets or similar business transaction, personal data may be transferred as part of that transaction.

Where required by Applicable Law, we will implement appropriate safeguards and provide any required notices before such transfer becomes effective.

6.5 Professional Advisers

We may disclose personal data to our professional advisers where reasonably necessary for the operation of our business, including:

• legal advisers;
• accountants;
• auditors;
• insurers;
• consultants; and
• other professional advisers acting under appropriate confidentiality obligations.

6.6 With Your Consent or Direction

We may disclose personal data where:

• you expressly request or authorise us to do so;
• you direct us to share information with another person or organisation;
• or you otherwise provide your consent where required by Applicable Law.

6.7 Aggregated and De-Identified Information

Kerja Xtra may use and disclose aggregated, statistical, anonymised or de-identified information that does not reasonably identify an individual User.

Such information may be used for business analytics, research, Platform improvement, market analysis and other lawful purposes.

6.8 No Sale of Personal Data

Kerja Xtra does not sell, rent or trade Users' personal data to third parties for monetary consideration.

If Applicable Law introduces additional rights relating to the sale or sharing of personal data in the future, Kerja Xtra will comply with those legal requirements.

Article 7 — International Data Transfers

Kerja Xtra may process or transfer personal data outside the country in which it was originally collected where reasonably necessary to operate the Platform.

Such transfers may occur because certain service providers, technical infrastructure or support services operate across multiple jurisdictions.

7.1 Circumstances of International Transfers

Personal data may be transferred internationally where reasonably necessary for purposes including:

• cloud hosting and infrastructure services;
• payment processing;
• identity verification;
• fraud prevention;
• cybersecurity;
• customer support;
• analytics;
• communications;
• backup and disaster recovery;
• or other services supporting the operation of the Platform.

7.2 Safeguards

Where personal data is transferred internationally, Kerja Xtra will take reasonable measures to ensure that the personal data continues to receive an appropriate level of protection consistent with Applicable Law.

Such measures may include, where appropriate:

• transferring personal data only where legally permitted;
• implementing contractual safeguards;
• conducting appropriate due diligence on service providers;
• requiring appropriate technical and organisational security measures;
• implementing internal policies governing international transfers; or
• applying any other safeguards required by Applicable Law.

7.3 Service Providers

Some of Kerja Xtra's trusted service providers may process personal data in countries other than the country in which the data was collected.

Those providers are required to process personal data only in accordance with Kerja Xtra's instructions, Applicable Law and appropriate contractual confidentiality and security obligations.

7.4 Your Acknowledgement

By using the Platform, you acknowledge that your personal data may be transferred to, stored in or processed in countries outside your country of residence where reasonably necessary for the operation of the Platform and where such transfers are permitted under Applicable Law.

Article 8 — Data Retention

Kerja Xtra retains personal data only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy, comply with Applicable Law and protect the legitimate interests of Kerja Xtra, its Users and third parties.

The retention period applicable to personal data depends on the nature of the information, the purposes for which it was collected and any applicable legal or regulatory requirements.

8.1 Purposes of Retention

We may retain personal data for purposes including:

• providing and operating the Platform;
• maintaining User Accounts;
• processing payments, Payment Holds, Wallets and Payouts;
• completing Verification processes;
• resolving Disputes;
• preventing fraud and abuse;
• responding to customer support requests;
• enforcing the Terms & Conditions and Platform policies;
• complying with Applicable Law; and
• establishing, exercising or defending legal claims.

8.2 Account Closure

If you close your Account, Kerja Xtra may retain certain personal data where reasonably necessary to:

• comply with legal or regulatory obligations;
• complete outstanding financial transactions;
• resolve ongoing Disputes;
• investigate fraud or abuse;
• enforce contractual obligations;
• protect the security and integrity of the Platform; or
• exercise or defend legal rights.

Closing an Account does not automatically require the immediate deletion of all personal data.

8.3 Legal and Regulatory Retention

Certain personal data may be retained for longer periods where required or permitted by Applicable Law, including obligations relating to:

• financial records;
• payment transactions;
• taxation;
• fraud prevention;
• dispute resolution;
• regulatory compliance; or
• law enforcement requests.

8.4 Anonymisation and Deletion

Where personal data is no longer required for the purposes described in this Privacy Policy, Kerja Xtra will, where reasonably practicable and subject to Applicable Law:

• permanently delete the personal data;
• anonymise or de-identify the personal data; or
• securely dispose of the personal data using appropriate technical or organisational measures.

Anonymised or de-identified information that can no longer reasonably identify an individual may be retained for lawful business purposes, including analytics, research, security and Platform improvement.

8.5 Residual Copies

Users acknowledge that limited copies of personal data may continue to exist for a reasonable period in secure backup systems, disaster recovery systems or archived records before being permanently deleted, where such retention is consistent with Applicable Law and industry-standard data management practices.

Article 9 — Data Security

Kerja Xtra is committed to protecting personal data against unauthorised access, disclosure, alteration, loss, misuse or destruction.

We implement reasonable technical, organisational and administrative measures designed to safeguard personal data throughout its lifecycle, taking into account the nature of the personal data, the risks involved and Applicable Law.

9.1 Security Measures

Kerja Xtra maintains appropriate safeguards designed to protect personal data, which may include:

• access controls and authentication measures;
• encryption or other appropriate security technologies;
• secure communication protocols;
• monitoring and logging of Platform activity;
• vulnerability management;
• fraud detection systems;
• employee access controls;
• internal security policies;
• staff training on data protection and security;
• business continuity and disaster recovery measures; and
• other reasonable safeguards appropriate to the operation of the Platform.

The specific security measures implemented by Kerja Xtra may evolve over time in response to technological developments, emerging threats and changes in Applicable Law.

9.2 User Responsibilities

Users also play an important role in protecting their personal data.

Users are responsible for:

• maintaining the confidentiality of their login credentials;
• using strong authentication credentials where available;
• protecting access to their devices;
• promptly notifying Kerja Xtra if they suspect unauthorised access to their Account;
• exercising appropriate caution when communicating with other Users; and
• taking reasonable steps to protect their own personal information.

9.3 Security Incidents

Despite our security measures, no method of electronic transmission, storage or processing of data can guarantee absolute security.

If Kerja Xtra becomes aware of a security incident involving personal data, we will take appropriate steps to:

• investigate the incident;
• contain and mitigate its effects;
• restore the security of affected systems where appropriate;
• assess any risks to affected individuals; and
• implement reasonable measures to reduce the likelihood of similar incidents occurring in the future.

9.4 Data Breach Notifications

Where required by Applicable Law, Kerja Xtra will notify:

• affected individuals; and/or
• the relevant regulatory or governmental authorities,

within the timeframes and in the manner prescribed by Applicable Law.

Where notification is not legally required, Kerja Xtra may nevertheless choose to notify affected Users where we reasonably believe that doing so would help them protect their interests.

9.5 No Absolute Security

While Kerja Xtra continually works to protect personal data, no security system is completely immune from risks.

Accordingly, Kerja Xtra cannot guarantee that personal data will never be accessed, disclosed, altered or destroyed by unauthorised parties.

Users acknowledge that they provide personal data through the Platform at their own risk, subject always to the obligations imposed on Kerja Xtra under Applicable Law.

Article 10 — Your Privacy Rights

Subject to Applicable Law, you may have certain rights regarding your personal data.

The availability and scope of these rights may vary depending on your country of residence, the nature of the personal data and the legal basis on which it is processed.

10.1 Right to Access

You may request confirmation of whether Kerja Xtra processes your personal data and, where permitted by Applicable Law, request access to that personal data and certain related information.

10.2 Right to Correction

You may request that inaccurate, incomplete or outdated personal data be corrected or updated.

Where appropriate, you may also update certain personal data directly through your Account settings.

10.3 Right to Deletion

You may request the deletion of your personal data where permitted by Applicable Law.

Kerja Xtra may retain certain personal data where continued retention is necessary to:

• comply with legal or regulatory obligations;
• complete outstanding transactions;
• resolve Disputes;
• prevent fraud;
• enforce the Terms & Conditions;
• establish, exercise or defend legal claims; or
• protect the security and integrity of the Platform.

10.4 Right to Restrict or Object

Where provided by Applicable Law, you may request that Kerja Xtra restrict certain processing activities or object to specific processing of your personal data.

Kerja Xtra will consider such requests in accordance with Applicable Law and our legitimate operational requirements.

10.5 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time.

The withdrawal of consent does not affect the lawfulness of any processing carried out before the consent was withdrawn.

Withdrawal of consent may affect the availability of certain Platform features where the relevant processing is necessary to provide those features.

10.6 Right to Data Portability

Where Applicable Law provides such a right, you may request a copy of certain personal data in a structured, commonly used and machine-readable format or request that such data be transmitted to another organisation where technically feasible.

10.7 Automated Decision-Making

Where Applicable Law grants rights relating to automated decision-making or profiling, Users may exercise those rights by contacting Kerja Xtra using the contact details provided in this Privacy Policy.

Where legally required, Kerja Xtra will provide appropriate safeguards, including human review where applicable.

10.8 Exercising Your Rights

To exercise any privacy rights available under Applicable Law, you may contact Kerja Xtra using the contact details provided in this Privacy Policy.

Before responding to a request, Kerja Xtra may require reasonable verification of your identity to protect the security of your personal data and prevent unauthorised access.

Kerja Xtra may decline or limit a request where permitted or required by Applicable Law, including where the request is manifestly unfounded, excessive or would adversely affect the rights of another person.

10.9 Complaints

If you believe that Kerja Xtra has processed your personal data in a manner that is inconsistent with Applicable Law, you may contact us so that we have an opportunity to address your concerns.

Where Applicable Law provides the right to do so, you may also lodge a complaint with the competent supervisory or regulatory authority.

Article 11 — Cookies, Analytics and Similar Technologies

Kerja Xtra uses cookies and similar technologies to operate the Platform, improve user experience, analyse Platform performance and enhance security.

These technologies may be used on the Kerja Xtra website, mobile application and other digital services that link to this Privacy Policy.

11.1 What Are Cookies and Similar Technologies?

Cookies are small text files stored on your device when you visit a website.

Depending on the Platform or device you use, Kerja Xtra may also use similar technologies, including:

• software development kits (SDKs);
• local storage;
• pixels;
• tags;
• device identifiers;
• application identifiers; and
• other technologies that perform similar functions.

For simplicity, this Privacy Policy refers to all of these technologies collectively as "Cookies and Similar Technologies."

11.2 How We Use Cookies and Similar Technologies

We may use Cookies and Similar Technologies for purposes including:

• operating and maintaining the Platform;
• authenticating Users;
• remembering User preferences;
• maintaining security;
• preventing fraud;
• measuring Platform performance;
• analysing usage patterns;
• improving existing features;
• developing new features;
• providing customer support; and
• complying with Applicable Law.

11.3 Types of Cookies and Similar Technologies

Depending on how you use the Platform, we may use:

Essential Technologies

These are necessary for the operation, security and functionality of the Platform.

Without them, certain features may not function correctly.

Analytics Technologies

These help us understand how Users interact with the Platform so that we can improve its performance, usability and reliability.

Where reasonably possible, analytics information is aggregated or de-identified.

Preference Technologies

These remember your settings and preferences to improve your experience across future visits.

Security Technologies

These help detect fraud, unauthorised access, abuse and other activities that may threaten the security or integrity of the Platform.

11.4 Third-Party Technologies

Kerja Xtra may use trusted third-party providers that deploy Cookies and Similar Technologies on our behalf for purposes such as:

• analytics;
• performance monitoring;
• fraud prevention;
• customer support;
• communications; or
• other operational purposes.

These providers process personal data only in accordance with Applicable Law and their contractual obligations to Kerja Xtra.

11.5 Managing Cookies

Depending on your browser, device or operating system, you may be able to manage, restrict or disable certain Cookies and Similar Technologies through your settings.

Please note that disabling certain technologies may affect the functionality, security or availability of some Platform features.

Where Applicable Law requires your consent before the use of certain Cookies or Similar Technologies, Kerja Xtra will obtain that consent through appropriate mechanisms before those technologies are activated.

11.6 Changes to Technologies

Kerja Xtra may introduce new Cookies and Similar Technologies as the Platform evolves.

This Privacy Policy applies to such technologies where they perform substantially similar functions and are used in accordance with Applicable Law.

Article 12 — Children's Privacy

The Platform is intended for individuals who are legally permitted to enter into binding contracts under Applicable Law.

Kerja Xtra does not knowingly collect personal data directly from children where such collection is prohibited by Applicable Law.

12.1 Minimum Age

Users must satisfy the minimum age requirements specified in the Terms & Conditions in order to create an Account and use the Platform.

By creating an Account, Users represent that they satisfy those eligibility requirements.

12.2 Unintentional Collection

If Kerja Xtra becomes aware that personal data has been collected from a child in circumstances where such collection is not permitted under Applicable Law, Kerja Xtra will take reasonable steps to:

• investigate the circumstances;
• delete or anonymise the relevant personal data where appropriate;
• suspend or terminate the relevant Account where necessary; and
• take any additional measures required by Applicable Law.

12.3 Parent or Guardian Requests

A parent or legal guardian who believes that a child has provided personal data to Kerja Xtra in violation of Applicable Law may contact us using the contact details provided in this Privacy Policy.

Kerja Xtra may request reasonable information to verify the identity and authority of the requesting parent or legal guardian before taking action.

12.4 Educational or Family Use

Nothing in this Privacy Policy prevents a parent or legal guardian from assisting a child in viewing publicly available information on the Platform where no Account is created and no personal data is submitted.

Article 13 — Changes to this Privacy Policy

Kerja Xtra may update this Privacy Policy from time to time to reflect changes in:

• the Platform;
• our services;
• applicable technologies;
• legal or regulatory requirements;
• security practices; or
• our business operations.

The most current version of this Privacy Policy will always be made available through the Platform.

13.1 Effective Date

The Privacy Policy will indicate the date on which it was last updated.

Unless otherwise stated, any revised version becomes effective from the date it is published.

13.2 Notification of Material Changes

Where required by Applicable Law or where Kerja Xtra considers it appropriate, we may notify Users of material changes to this Privacy Policy through one or more of the following methods:

• notifications within the Platform;
• email;
• SMS;
• push notifications;
• publication on the Platform; or
• any other reasonable communication method.

13.3 Continued Use

Where permitted by Applicable Law, your continued use of the Platform after the effective date of an updated Privacy Policy constitutes your acknowledgement of the revised Privacy Policy.

Where Applicable Law requires your consent for specific changes affecting the processing of personal data, Kerja Xtra will obtain such consent before implementing those changes.

Article 14 — Contact Us

If you have any questions, requests or concerns regarding this Privacy Policy or the processing of your personal data, you may contact Kerja Xtra using the contact details below.

PT Villa Management Bali
Operator of the Kerja Xtra Platform

Email: info@kerjaxtra.com
Website: https://kerja-xtra.com

Where applicable, requests relating to the exercise of privacy rights should include sufficient information to enable Kerja Xtra to verify the identity of the requester and understand the nature of the request.

Kerja Xtra will make reasonable efforts to respond to privacy-related requests within the timeframes required by Applicable Law.

If additional information is required to process a request, Kerja Xtra may contact the requester for further verification or clarification.