Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how PT Holink Solusi Digital (“Holink”, “we”, “us”, or “our”) collects, uses, discloses, stores, and protects Personal Data of users in connection with the access to and use of the Holink Platform and Services.

This Privacy Policy forms an integral and inseparable part of the Terms and Conditions of Use (“Terms of Use”). Unless otherwise defined herein, capitalized terms used in this Privacy Policy shall have the same meaning ascribed to them under the Terms of Use.

By accessing, registering, and/or using the Services, the User acknowledges that they have read, understood, and agreed to this Privacy Policy.

General Provisions

A. Holink processes Personal Data in accordance with:

Applicable laws and regulations of the Republic of Indonesia; and
This Privacy Policy and the Terms of Use.

B. This Privacy Policy applies to all Users of the Holink platform, including Users of free plans and paid subscription plans.

C. Holink reserves the right to amend or update this Privacy Policy from time to time. Any amendment shall become effective upon publication on the Holink platform.

Personal Data Collected by Us

A. The Personal Data collected by Holink may include, but is not limited to:

Identity Data, such as name, email address, username, other account-related information provided by the User.
Technical Data, such as IP address, device type, operating system, browser type, activity logs;
Transaction Data, including subscription plan details, billing and payment records, User’s subscription status; and
Content Data, namely User content that is linked, uploaded, managed, or processed through the Holink platform.

B. Holink does not intentionally collect sensitive personal data, unless required by applicable law or expressly provided by the User.

Methods of Collection of Personal Data

Holink may collect Personal Data through:

A. Registration and creation of a Holink account;

B. Use of the Services and platform features;

C. Communications between the User and Holink;

D. Cookies and similar technologies; and/or

E. Other lawful sources permitted under applicable laws.

Purpose of the Use of Personal Data

Holink processes Personal Data for the following purposes:

A. To provide, operate, and manage the Holink Services;

B. To verify identity and administer User accounts;

C. To process subscriptions and payments;

D. To improve features, security, and user experience;

E. To deliver service-related notices, updates, and policy communications;

F. To handle inquiries, complaints, and support requests; and

G. To comply with legal and regulatory obligations.

Disclosure of Personal Data

A. Holink may disclose Personal Data on a limited basis to:

Third-party service providers (such as payment processors, hosting providers, analytics services);
Business partners supporting the operation of the Services; and/or
Competent authorities, where required by law or legal process.

B. Any disclosure shall be limited to what is necessary and relevant for the intended purpose.

C. Holink does not sell Users’ Personal Data to any third party.

Retention of Personal Data

A. Personal Data shall be stored for as long as necessary to:

Fulfill the purposes set out in this Privacy Policy; and/or
Comply with applicable legal obligations.

B. Holink may retain Personal Data after account termination to the extent required or permitted by law.

Cross-Border Transfer of Personal Data

Where Personal Data is transferred outside the territory of the Republic of Indonesia, Holink shall ensure that:

A. The recipient jurisdiction provides an adequate level of data protection; or

B. Appropriate safeguards are implemented in accordance with applicable laws.

Deletion and Destruction of Personal Data

A. Personal Data shall be securely destroyed when:

It is no longer required for processing purposes;
Upon the request of the User; and/or
There is no legal obligation to retain such data.

B. Destruction shall be conducted in a manner that prevents unauthorized access or recovery.

Security of Personal Data

A. Holink implements reasonable technical and organizational measures to protect Personal Data against:

Unauthorized access;
Loss;
Misuse; or
Unlawful disclosure

B. In the event of a Personal Data protection failure, Holink shall notify the User and/or the competent authority in accordance with the applicable laws and regulations.

C. Users acknowledge and agree that despite Holink’s implementation of reasonable technical and organizational safeguards, no electronic system or data transmission over the internet is completely secure or immune from unauthorized access, disruptions, or cyberattacks.

D. Users are responsible for maintaining the confidentiality of their Account credentials, including passwords and other access information, and are fully responsible for all activities conducted through their Account.

E. Holink shall not be liable for any data security breach caused by User negligence, credential sharing, use of unsecured devices, or third-party attacks beyond Holink’s reasonable control.

F. Users must promptly notify Holink upon becoming aware of or suspecting any unauthorized access, account misuse, or other security breaches.

User Rights

A. Subject to applicable laws, the User have the following rights as data subjects:

To access their Personal Data processed by Holink;
To request correction, updating, or rectification of inaccurate or incomplete Personal Data;
To withdraw consent for certain Personal Data processing, to the extent such processing is based on consent;
To object to, lodge complaints against, or request restriction of Personal Data processing in accordance with applicable laws; and/or
To request deletion or destruction of Personal Data in accordance with applicable laws.

B. The withdrawal of consent by Users may result in limitations or termination of part or all of the Services, to the extent such Personal Data processing is necessary for the provision, operation, or legal compliance of Holink’s Services.

C. The User may exercise their Personal Data rights, including requests for Personal Data deletion, through Holink’s official support channels as designated from time to time, including through Holink’s official customer service email or the help feature on Holink’s application or official website.

D. Upon receiving a deletion request, Holink will conduct an initial review of the credibility of the data and the User’s identity and may require the User to complete a data deletion form provided by Holink as part of the verification and approval process for the deletion of Personal Data. The data deletion form is available at the following link: https://forms.gle/nBGscDu2tSrNUFQq9

E. Every request for deletion of Personal Data will be recorded in Holink’s system and processed for record keeping, audit, and process security purposes, including retention of the deletion form approved by the User.

F. To prevent unauthorized or fraudulent Personal Data deletion, Holink Customer Support will require additional verification from Users, including but not limited to:

Confirmation of the email address registered to the Holink Account; and
Completion of and consent to the account deletion form or other written approval, including a digital signature if required.

G. Once the verification process is deemed complete and valid and the deletion form has been approved by the User, Holink’s internal team will delete the User’s Personal Data in accordance with this Privacy Policy and applicable laws and regulations.

H. Holink will notify the User through the support ticket regarding the status of the Personal Data deletion request, including whether the request has been approved, completed, postponed, or rejected, along with the relevant reasons.

I. Holink may refuse or delay a Personal Data deletion request if:

The verification process is not satisfied or there are indications of an unauthorized request; and/or
Such Personal Data is still required to comply with legal obligations, legitimate interests, dispute resolution, or applicable laws and regulations.

J. Holink will respond to Users’ requests relating to Personal Data rights within a maximum of 14 (fourteen) business days from the date the complete and verified request is received.

Acknowledgement and Consent

A. By using the Holink platform and Services, the User represents and warrants that:

The Personal Data provided is accurate and lawful;
The User grants consent to Holink to process Personal Data in accordance with this Privacy Policy; and
The User understands that such processing is necessary for the provision of the Services.

B. If the User does not agree with this Privacy Policy, the User must immediately discontinue use of the Services.

User Responsibility for Content, Links, and Misuse

A. Users are solely responsible for all content, links, and materials published, shared, or linked through their respective Holink Accounts.

B. Holink does not verify, actively monitor, or guarantee the legality, safety, or accuracy of any content or links shared by Users.

C. Any use of the Holink Platform for fraud, phishing, scams, impersonation, or other unlawful activities is entirely outside Holink’s responsibility.

D. Holink shall not be liable for any losses, damages, or privacy violations arising from third-party access to or use of User-shared content or links.

E. Without prejudice to its other rights, Holink may remove content, restrict access, or suspend Accounts upon becoming aware of abuse or violations of applicable laws or the Terms of Use.

Public Profile Content Visibility

A. Holink provides a platform for Users to publish links and content through a public profile page.

B. All links, text, images, and other content added by Users to their public profiles may be publicly accessible by anyone who has or discovers the profile URL.

C. Users acknowledge that information chosen to be displayed publicly is no longer private.

D. Holink does not control and is not responsible for how third parties access, use, copy, or redistribute publicly available content.

E. Users are responsible for ensuring that shared content does not violate privacy rights, intellectual property rights, or applicable laws in Republic of Indonesia.

Governing Law and Legal Basis for Personal Data Processing

The processing of Personal Data by Holink is carried out in accordance with the applicable laws and regulations of the Republic of Indonesia and based on one or more lawful legal bases, including but not limited to:

A. The User’s consent, as lawfully given through the use of the Holink Platform and/or Services;

B. The performance of an agreement between Holink and the User, including but not limited to the provision, management, and operation of the Services;

C. The fulfillment of legal obligations applicable to Holink in accordance with the prevailing laws and regulations; and/or

D. Holink’s legitimate interests, provided that such processing is conducted in a proportional and relevant manner and does not conflict with the rights and freedoms of the User as the Personal Data subject.