Privacy Policy



1.1 Welcome to the platform which is operated by PT Hartadinata Abadi, tbk and its affiliates and subsidiaries (individually and collectively also referred to as "Emaskita" or "we"). Emaskita takes responsibilities under applicable privacy laws and regulations ("Privacy Laws") and is committed to respecting the privacy rights and concerns of all Users of our Gold Platform ("Platform") (collectively we call the Platform and services which we provide as described on our Site as the "Services"). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.


1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from such data, or from other data and information that an organization can or is likely to have access to. Common examples of personal data may include names, identification numbers and contact information.


1.3 By using the Service, registering an account with us, visiting our Platform, or accessing the Service, you acknowledge and agree that you accept the practices, terms and/or policies described in this Privacy Policy, and you hereby consent to us collecting, using , disclose and/or process your personal data as described herein. IF YOU DO NOT ALLOW THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will post the changes or the modified Privacy Policy on our Platform. We reserve the right to change this Privacy Policy at any time.


1.4 This policy applies with respect to other notices, contract clauses, consent clauses that apply in relation to our collection, storage, use, disclosure and/or processing of your personal data and is not intended to override such notices or clauses unless we state otherwise.




2.1 We will/may collect your personal data:

• when you register for and/or use our Services or Platform, or open an account with us.

• when you submit any form, including, but not limited to, application forms or other forms relating to our products and services, whether online or in physical form;

• when you enter into agreements or provide documents or other information in connection with your interactions with us, or when you use our products and services;

• when you interact with us, such as by telephone (which may be recorded), letters, faxes, face-to-face meetings, social media platforms and email, including when you interact with our customer service agents;

• when you use our electronic services, or interact with us through our applications or use services on our Platform. This includes, without limitation, through cookies that we may use when you interact with our applications or websites;

• when you give your device permission to share information with our applications or Platforms;

• when you link your Emaskita account with your social media or other external accounts or use other social media features, in accordance with the provider's policy;

• when you make transactions through our Services;

• when you submit criticisms and suggestions or complaints to us;

• when you submit your personal data to us for any reason.

The above list is not intended to be an exhaustive list and only sets out some general examples of when your personal data may be collected.




3.1 Personal data that may be collected by Goldkita includes but is not limited to:

• name;

• email address;

• billing address;

• bank account and payment information;

• phone number;

• gender;

• TIN number;

• ID card number;

• information sent by or connected to the device(s) used to access our Services or Platforms;

• information about your network and the people and accounts you interact with;

• government-issued identification or other information necessary for our due diligence, getting to know your customer, identity verification, or fraud prevention purposes;

• any other information about the User when the User registers to use our Service or Platform, and when the User uses the Service or Platform, as well as information relating to how the User uses our Service or Platform; and

• all data about the content used by the User.


3.2 You agree not to submit any inaccurate or misleading information, and you agree to notify any inaccuracies or changes to such information. We reserve the right at our discretion to require further documentation to verify the information submitted by you.





4.1 Like most websites and mobile applications, your device sends information which may include data about you which a web server can log when you use our Platform. This typically includes without limitation, your device's Internet Protocol (IP) address, computer/mobile device operating system, and browser type, type of mobile device, characteristics of the mobile device, unique device identifier (UDID) or mobile equipment identifier (MEID) for mobile devices. you, the address of the recommending site (if any), the pages you visited on our website and mobile applications and the time of your visit, and sometimes "cookies" (which can be disabled using your browser preferences) to help the site remember your recent visit. final. If you are logged in (login), this information is associated with your personal account. This information is also included in anonymous statistics to enable us to understand how visitors use our site.


4.2 Our mobile application may collect detailed location information from mobile devices using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process information for one or more purposes, without limitation, location-based services that you request or to deliver content to you based on your location or to allow you to share your location with other Users as part of services on the application. our mobiles. For most mobile devices, you can withdraw the consent you gave us to obtain this information at your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or device manufacturer.


4.3 Such as when you view a page of our website or mobile application, when you watch content and advertisements and access other software on our Platform or through the Services, most of the same information is sent to us (including, without limitation, IP Address, operating system and others); however, instead of a page view, your device sends us information about the content, advertisements viewed and/or software installed by the Service and Platform and the time.




5.1 From time to time, we or our authorized service providers may use "cookies" or other features to enable us to collect or share information in connection with your use of the Services or the Platform. These features help us improve our Platform and the Services we offer, or help us offer new services and features. “Cookies” are identifiers stored on your computer or mobile device that record data about your computer or device how and when the Service or Platform is used or visited, by how many people, and other activities on our Platform. We may link cookie information to personal data. Cookies also link to information about what items you have selected for purchases and which web pages you view.


5.2 You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do this, you will not be able to use the full functionality of our Platform or Services.




6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:


• consider and/or process your application/transaction with us or your transactions or communications with third parties through the Service;

• manage, operate, provide and/or administer your use of and/or access to our Services and our Platform (including, but not limited to, remembering your preferences), as well as your relationship and your user account with us;

• respond to, process, deal with or complete transactions and/or fulfill your requests for certain products and services and notify you of service issues and unusual account actions;

• enforce any applicable Terms of Service or end user license agreement;

• protect personal safety and the rights, property or safety of others;

• for identification, verification. due diligence, or know your customer's goals;

• to evaluate and make decisions regarding your credit or risk profile and your eligibility to obtain loan products;

• maintain and provide any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;

• dealing with or facilitating customer service, carrying out your instructions, dealing with or responding to any questions raised by (or purportedly raised by) you or on your behalf;

• contact you or communicate with you by telephone call, text message and/or fax message, email and/or postal mail or other means for the purpose of administering and/or managing your relationship with us or your use of our Services, such as but not limited to on communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us can be done by sending a letter, document or notice to you, which may involve disclosing certain personal data about you to make such delivery as well as listed on the outer cover of the postal envelope/package;

• allow other Users to interact, connect with you or view some of your activity on the Platform, including notifying you when another User has sent you a private message, posted comments for you on the Platform or connected with you using social features on the Platform;

• conduct research, analysis and development activities (including, but not limited to, data analysis, surveys, product and service development and/or profiling), to analyze how you use our Services, improve our Services or products and/or improve your experience your customers;

• enable audits and surveys to, among other things, validate the size and composition of our target audience, as well as understand their experience with our Gold Service;

• for marketing and advertising, and in this case, sending you through various modes of communication, marketing and promotional information and materials relating to products and/or services (including, but not limited to products and/or services of third parties collaborating or related with Emaskita) which Emaskita (and/or its affiliates, or related corporations) may sell, market or promote, whether the product or service exists now, or is created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function in the electronic marketing materials. We may use your contact information to send newsletters from us and from companies associated with us;

• respond to legal process or comply with or as required by any applicable law, governmental or regulatory requirements of the relevant jurisdiction or if we have a good faith belief that such disclosure is necessary, including, without limitation, meeting the requirements to make disclosures under requirements laws that are binding on Emaskita or its related companies or affiliates (including, where applicable, the display of your name, contact details and company details);

• produce statistics and research for internal reporting and as required by law and/or archival requirements;

• perform due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that have been imposed by us;

• to carry out risk and/or credit assessments and to determine the products or terms, including credit products, financial services, or other products (as applicable), that are provided by either Emaskita or its affiliates, to be offered to you;

• audit our Services or our Gold business;

• prevent or investigate actual or suspected breaches of the Terms of Service any fraud, unlawful activity, omission or wrongdoing, whether related to your use of our Services or any other matter arising out of your relationship with us;

• respond to threatened or actual claims brought against Goldkita or any other claims that any Content violates the rights of third parties;

• store, maintain, back up (whether for disaster recovery or otherwise) your personal data, whether within or outside your jurisdiction;

• dealing with/and facilitating business asset transactions or possible business asset transactions, in which the transaction involves Emaskita as a participant or only involving Goldkita's related or affiliate companies as participants or involving Emaskita and/or one or more of Emaskita's related companies or affiliates as participants , and there may also be other third party organizations that are participants in the transaction. “Business asset transaction” refers to the purchase, sale, lease, merger, consolidation or any other form of acquisition, disposal or financing of an organization or part of an organization or any business or assets of an organization; and/or

• any other purposes which we will notify you of upon obtaining your consent.


(collectively, the “Purposes”).


6.2 You acknowledge, agree and agree that Emaskita may access, store and disclose your information and Account Content if required by law or pursuant to a court order or by a priority government or regulator that has jurisdiction over Emaskita or in a good faith belief that the storage or disclosure of access it is reasonably necessary to: (a) comply with legal process; (b) comply with requests from any governmental or regulatory authority that has jurisdiction over Goldkita; (c) enforce our Gold Terms of Service or this Privacy Policy; (d) respond to any threatening or actual claim against Emaskita or any other claim that any Content violates the rights of a third party; (e) respond to your requests for customer service; or (f) protect rights,


6.3 Since the purposes for which we will/may collect, use, disclose or process your personal data depend on the situation at hand, those purposes may not be listed above. However, we will notify you of such other purposes upon obtaining your consent, unless the applicable data processing without your consent is permitted by the Privacy Laws.




7.1 We implement various security measures and strive to ensure the security of your personal data in our systems. Users' personal data resides behind a secure network and can only be accessed by a small number of employees who have special access rights to the system. However, the absence of absolute guarantees or security is unavoidable.


7.2 We will retain personal data in accordance with the Privacy Act and/or other applicable laws. That is, we will destroy or anonymize your personal data when we reasonably deem that (i) the purpose for which the personal data was collected is no longer being served by the storage of that personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) there is no warrant that legitimizes the further withdrawal of the personal data. If you stop using our Platform, or your permission to use the Platform and/or Services is terminated or withdrawn, we may continue to store, use and/or disclose your personal data in accordance with our Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law,




8.1 In conducting our business, we will/may need to use, process, disclose and/or transfer your personal data to third party service providers, agents and/or affiliates or related companies, and/or other third parties, whether may be located in Indonesia or outside Indonesia, for one or more of the above-mentioned Purposes. Such third party service providers, agents and/or affiliates or related companies and/or other third parties will process your personal data on behalf of us or other parties, for one or more of the above-mentioned Purposes. We strive to ensure that our third parties and affiliates maintain the security of your personal data from unauthorized access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is required for the above-mentioned Purposes. Such third parties include, without limitation:


• our subsidiaries, affiliates and related companies;

• buyers or sellers who have transacted or interacted with you on the Platform or in connection with your use of the Services for the above-mentioned Purposes;

• Other users of the Platform for one or more of the above-mentioned Purposes;

• contractors, agents, service providers and other third parties we use to support our business. This includes but is not limited to parties who provide administrative or other services to us such as postal services, logistics service providers, financial service providers, telecommunications companies, information technology companies and data centers;

• Emaskita Affiliates or other third parties to which you have linked your Emaskita account with such third parties by using “Connect with Emaskita” or other similar features;

• governmental or regulatory authorities that have jurisdiction over Goldkita or as permitted under Section 6.2;

• purchaser or other successor in the event of a merger, divestment, restructuring, reorganization, dissolution or other sale or transfer of some or all of our Gold assets, whether on an ongoing basis or as part of a bankruptcy, liquidation or similar process, where personal data held by Emaskita about Users of our Service is one of the assets transferred; or to partners in a business asset transaction involving Emaskita or one of its affiliates or related companies; and

• third parties to whom we disclose the data for one or more Purposes and such third parties will in turn collect and process your personal data for one or more Purposes


8.2 This may require, among other things, for us to share information, including statistical and demographic information, about our Users and information regarding their use of the Service with advertising and programming suppliers. This will not include anything that can be used to specifically identify you or find personal information about you.


8.3 For the avoidance of doubt, in the event that the Privacy Act or other applicable law permits an organization such as us to collect, use or disclose your personal data without your consent, the consent granted by such law will continue in effect.


8.4 Third parties may intercept or access personal data transmitted to or stored on the site without permission, technology may malfunction or not work as expected, or someone may access, utilize or misuse information without any fault on our part. However we will use reasonable security arrangements to protect your personal data as required by the Privacy Laws; however unavoidably, there are no absolute security guarantees such as but not limited to unauthorized disclosure arising from malicious and sophisticated hacking by disgruntled or hostile parties without any fault on our part.


8.5 Emaskita allows you to share videos from YouTube within the Goldkita Live Stream feature (“YouTube Content”). To facilitate this, Emaskita uses the YouTube API Service provided by YouTube. By using YouTube Content sharing, you hereby agree to be bound by Google's Privacy Policy (


8.6 As set forth in our Gold Service Terms, Users (including any employee, agent, representative, or any other person acting on behalf of such User or on behalf of the User) who has personal data of other Users through the use of the Service (“Recipient Party”) hereby agree that, they will (i) comply with all applicable Privacy Laws with respect to such data including any collection, processing, storage or transfer of such data, (ii) permit Emaskita or Users whose personal data has been collected by the Receiving Party (“Party the Discloser”) to delete its collected data from the Receiving Party's database; and (iii) allow Goldkita or the Disclosing Party to review what information has been collected about them by the Receiving Party,


8.7 Notwithstanding any other provisions set forth herein, Seller (including any employee, agent, representative, or any other person acting on behalf of such Seller or on behalf of Seller) must comply with all applicable Privacy Laws and, with respect to the personal data of any purchaser received from Emaskita, (i) is not permitted to use the personal data of such buyers except as reasonably necessary to respond to buyer inquiries and to respond to, process, handle or complete transactions without the prior written consent of the buyer and Emaskita; (ii) must refrain from contacting buyers using such information outside the Emaskita platform; (iii) is not permitted to disclose the personal data of the buyer to unauthorized third parties without the prior written consent of the buyer and Emaskita; (iv) must use adequate security measures to protect the personal data of any Goldkita users in their possession, retain such data only for as long as is necessary for the purposes stated above and in accordance with the Privacy Laws, and to delete or return such data to Emaskita whenever requested by Emaskita or as soon as possible after completing a transaction; and (v) to notify our Gold Personal Data Protection Officer at retain such data only for as long as necessary for the purposes stated above and in accordance with the Privacy Laws, and to delete or return such data to Emaskita whenever requested by Emaskita or as soon as possible after completing a transaction; and (v) to notify our Gold Personal Data Protection Officer at retain such data only for as long as necessary for the purposes stated above and in accordance with the Privacy Laws, and to delete or return such data to Emaskita whenever requested by Emaskita or as soon as possible after completing a transaction; and (v) to notify our Gold Personal Data Protection Officer in the event of a potential data breach or loss of user data.




9.1 The Services are not directed at children under the age of 13. We do not knowingly collect or store any personal data or non-personal information from anyone under the age of 13 and any part of our Platform or other Services is not directed at children under the age of 13. As a parent or legal guardian, please do not give permission for children under your care to submit personal data to Emaskita. In the event that personal data of children under the age of 13 who are under your care is disclosed to Emaskita, you hereby consent to the processing of the child's personal data and accept and agree to be bound by this Privacy Policy on behalf of the child.




10.1 Our platform uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your device, to help Platom analyze how users use the Platform. Information generated by cookies regarding your use of the Platform (including your IP address) will be transmitted to, and stored by Google on servers in the United States. Google will use this information for the purposes of evaluating your use of our Platform, compiling reports on website activity for website operators and providing other services related to website activity and Internet usage. Google may also transfer this information to third parties where required by law to do so, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.


10.2 We, and third parties, may from time to time provide downloads of software applications for your use on the Platform or through the Services. All of these applications may separately access, and allow third parties to view, information that can identify you, such as your name, User ID, IP Address of your device or other information, such as what cookies may be pre-installed, or which were installed for you. by third party software applications or websites. In addition, these applications may ask you to provide additional information directly to third parties. Third party products or services through these applications are not owned or controlled by Emaskita.




11.1 WE DO NOT WARRANT THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to keep your personal data safe in our possession or under our control. Your personal data is stored behind a secure network and can only be accessed by a limited number of people who have special access rights to the system, and are required to maintain the confidentiality of the personal data. When you place an order or access personal data, we offer the use of a secure server. All personal data or sensitive information that you provide is encrypted into our database and can only be accessed as stated above.


11.2 In an effort to provide you with increased value, we may select various third party websites to link to, and frame within the Platform. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. All these linked sites have their own independent privacy policies and security settings. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has its own privacy and data collection practices separate from ours. Data collected by our co-branded partners or third party websites (even, if offered on, or through our Platform) may not be received by us.


11.3 Therefore, we are neither responsible nor liable for the content, security settings (or lack thereof), and activity of these linked sites. These linked sites are for your convenience only, and you therefore access them at your own risk. However, we strive to protect the integrity of our Platform and the links placed on each site, and as such, we welcome any feedback regarding these linked sites (including, but not limited to, if certain links do not work). .




12.1 Your personal data and/or information may be transferred, stored or processed outside your country for one or more Purposes. Emaskita will only transfer your information overseas in accordance with the Privacy Act.





If you have any questions or concerns about our privacy practices please contact us by e-mail at
Last modified on: 24-03-2022 09:49:46