Privacy Policy

1. Introduction

At Seadev (“Company”, “we”, “our”, or “us”), we are committed to protecting the privacy of our clients and any individuals who interact with us. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information. By engaging with our services, you agree to the collection and use of your information in accordance with this policy.

2. Information We Collect

We may collect the following types of personal information (“Personal Information”):

• Identifiers
  • Name
  • Email address
  • Phone number
  • Mailing and billing address
• Financial Information:
  • Payment details necessary for processing transactions
• Commercial Information:
  • Records of services purchased or considered
• Professional or Employment-Related Information:
  • Company name
  • Job title
• Internet or Other Electronic Network Activity Information:
  • Interaction with our emails and electronic communications

3. How We Collect Information

We collect Personal Information through:

• Direct Interactions:
  • When you contact us via email or phone to inquire about or use our services
  • When you provide information necessary for the delivery of our services
• Automatic Data Collection Technologies:
  • We do not use cookies or similar tracking technologies on our website

4. Use of Personal Information

We use your Personal Information for the following purposes:

• Providing Services:
  • To deliver the services you have requested
  • To process transactions and billing
• Improving Our Services:
  • To understand how our services are used and to enhance them
• Marketing and Communications:
  • To send you promotional materials and communications about our services
  • Opt-Out: You may opt out of marketing communications at any time by contacting us
• Responding to Inquiries:
  • To address your questions, comments, and requests
  • To provide customer support
• Legal Obligations:
  • To comply with legal and regulatory requirements

5. Legal Basis for Processing

We process your Personal Information based on the following legal grounds:

• Consent:
  • Where you have provided consent for specific purposes
• Performance of a Contract:
  • Processing is necessary to provide the services you have requested
• Legitimate Interests:
  • For our legitimate business interests in providing and improving our services, provided that your interests and fundamental rights do not override those interests
• Legal Obligations:
  • Compliance with legal and regulatory obligations to which we are subject

6. Disclosure of Personal Information

We do not sell, rent, or trade your Personal Information to third parties. We may disclose your Personal Information only under the following circumstances:

• Service Providers:
  • We may share information with third-party service providers who assist us in operating our business, such as payment processors, subject to contractual obligations to maintain the confidentiality and security of your data
• Legal Obligations:
  • To comply with applicable laws, regulations, or legal processes
  • To respond to lawful requests by public authorities, including for national security or law enforcement purposes
• Business Transfers:
  • In connection with a merger, acquisition, or sale of all or a portion of our assets

7. International Data Transfers

We may transfer your Personal Information to countries outside of your country of residence, including to our headquarters in Indonesia, for processing and storage. By providing your Personal Information, you consent to such transfers.

• Safeguards:
  • We take appropriate measures to ensure that international transfers comply with applicable data protection laws and that your Personal Information remains protected
  • These measures include implementing standard contractual clauses approved by relevant authorities and ensuring robust data security practices

8. Data Retention

We retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements.

• Retention Period:
  • The criteria for determining retention periods include the nature of the information and the purposes for processing
  • We will retain your information until it is no longer necessary for the purposes collected

9. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your Personal Information:

• Access:
  • Request information about the Personal Information we hold about you
• Correction:
  • Request correction of inaccurate Personal Information
• Deletion:
  • Request deletion of your Personal Information when there is no lawful basis for us to continue processing it
• Restriction of Processing:
  • Request that we restrict the processing of your Personal Information under certain circumstances
• Data Portability:
  • Request a copy of your Personal Information in a structured, commonly used, and machine-readable format
• Objection:
  • Object to the processing of your Personal Information based on legitimate interests or for direct marketing purposes
• Automated Decision-Making:
  • Request human intervention if you are subject to a decision based solely on automated processing, including profiling
• Non-Discrimination:
  • We will not discriminate against you for exercising any of your privacy rights

10. Exercising Your Rights

To exercise your rights, please contact us using the contact information provided below. We will respond to your request within the timeframes required by applicable law.

• Verification:
  • To protect your privacy, we may need to verify your identity before processing your request
• Authorized Agents:
  • You may designate an authorized agent to make a request on your behalf, subject to verification

11. Additional Rights for Residents of Certain U.S. States

Residents of certain U.S. states may have additional rights under state-specific privacy laws, including:

• California Privacy Rights Act (CPRA)
• Colorado Privacy Act (CPA)
• Virginia Consumer Data Protection Act (VCDPA)
• Utah Consumer Privacy Act (UCPA)
• Texas Data Privacy and Security Act (TDPSA)
• Florida Digital Bill of Rights (FDBR)
• Montana Consumer Data Privacy Act (MCDPA)

Specific Rights Under These Laws:

• Right to Know:
  • You may request that we disclose the following:
  • Categories and specific pieces of Personal Information we have collected about you
  • Categories of sources from which Personal Information is collected
  • Business or commercial purpose for collecting, sharing, or selling Personal Information
  • Categories of third parties with whom we disclose Personal Information
• Right to Delete:
  • You may request that we delete Personal Information we have collected from you, subject to certain exceptions
• Right to Correct:
  • You may request correction of inaccurate Personal Information
• Right to Opt-Out of Sale or Sharing:
  • You have the right to opt-out of the sale or sharing of your Personal Information for targeted advertising purposes
  • Note: We do not sell or share Personal Information as defined under applicable state laws
• Right to Limit Use of Sensitive Personal Information:
  • If applicable, you may limit the use of your sensitive Personal Information to certain permitted purposes
  • Note: We do not collect or process sensitive Personal Information as defined under applicable state laws

Exercising Your Rights:

Residents of these states can exercise their rights by contacting us using the information provided in the Contact Information section.

12. Data Security Measures

We implement appropriate technical and organizational measures to protect your Personal Information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption:
  • Data is encrypted in transit using Secure Sockets Layer (SSL) technology
• Access Controls:
  • Personal Information is accessible only to authorized personnel who require access to perform their job functions
• Two-Factor Authentication (2FA):
  • We utilize 2FA to add an extra layer of security to our systems
• Firewalls and Intrusion Detection:
  • Protection against unauthorized access and cyber threats
• Regular Security Audits:
  • Periodic reviews and testing of our security practices
• Employee Training:
  • Employees are trained on data protection best practices and are required to maintain the confidentiality of Personal Information

13. Data Breach Notification

In the event of a data breach that compromises the security of your Personal Information, we will notify you and the appropriate supervisory authorities as required by applicable laws.

• Notification Timeframe:
  • We will notify affected individuals without unreasonable delay and within the timeframes specified by applicable laws

14. Children's Privacy

Our services are not intended for individuals under the age of 16. We do not knowingly collect Personal Information from children under 16. If you believe we have inadvertently collected such information, please contact us so we can take appropriate measures.

15. Do Not Track Signals

Our website does not track users over time and across third-party websites and therefore does not respond to Do Not Track (DNT) signals.

16. Changes to This Privacy Policy

We may update our Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will indicate the effective date of the latest version at the top of the policy. Your continued use of our services after any changes signifies your acceptance of the updated Privacy Policy.

17. Contact Information

If you have any questions or concerns about this Privacy Policy or our data practices, or if you wish to exercise your privacy rights, please contact us:

• Email: support@seadev.com.au
• Phone: +1 (508) 446-3683
• Mailing Address:
  Seadev
  The Kensington Office Tower Building, Jl. Boulevard Raya No. 1, 2nd Floor, Room B2
  Jakarta, DKI Jakarta, 14350
  Indonesia

18. Policy Accessibility

This Privacy Policy is accessible on our website at https://seadev.com.au/privacy-policy. If you require this policy in an alternative format, please contact us using the information provided above.

19. Governing Law

This Privacy Policy shall be governed and construed in accordance with the laws of Indonesia, without regard to its conflict of law provisions.

20. Effective Date

This Privacy Policy is effective as of 17 Dec 2024.