Definition and Interpretation

To ensure the interpretation of each term used in this policy, the definitions of each term are as follows:

1. “User Account” is an access identity created by the user on the Maquira platform, which contains Personal Data, login credentials, preferences, and other information necessary to use certain services. The account is used as a means of authentication and authorization, and any activity carried out through the account is considered a valid action by the user.

2. “Personal Data” is data about individuals, business entities, or legal entities that are identified or can be identified individually and/or in combination with other information, either directly or indirectly, through electronic or non-electronic systems.

3. “Information” is any description, statement, idea, and sign that contains value, meaning, and messages, whether data, facts, or explanations that can be seen, heard, and read, presented in various packages and formats in accordance with developments in electronic and non-electronic information and communication technology.

4. “Personal Data Controller” is any person, public agency, and international organization acting alone or jointly in determining the purpose and exercising control over the processing of Personal Data.

5. “Personal Data Protection” is the overall effort to protect Personal Data in the processing of Personal Data to guarantee the constitutional rights of the subject of Personal Data.

6. “Company” is Maquira and all entities owned, controlled, or operated by Maquira and responsible for the provision, management, development, and operation of platforms, services, products, content, and related business processes. The term “Company” in this document also includes management, employees, representatives, consultants, and other parties who legally act on behalf of Maquira in providing services to users.

7. “Processing” means any action taken on any form of Personal Data, including but not limited to collection, storage, use, alteration, deletion, disclosure, and the like.

8. “Promoter” is an individual or legal entity that has been registered, verified, and approved by Maquira to carry out promotional, marketing, product education, events, or certain commercial activities that support Maquira's operations in accordance with company policy. Promoters are not employees of Maquira and all marketing activities must be carried out in accordance with official guidelines, codes of conduct and prohibitions established by Maquira and applicable laws and regulations.

9. “Consumer” is any person who uses goods and/or services available in the community, whether for their own interests, their family, other people, or other living beings, and not for trade.

10. “Service Provider” is PT. Maquira Patagonia Indonesia, which owns and operates the maquira.com platform and is responsible for managing digital services, including but not limited to: websites, applications, membership systems, and User data centers, either directly or indirectly.

Legal Basis for the Collection and Purpose of Personal Data Collection

The Company collects and processes your Personal Data based on the following:

1. Agreement.
   All forms of rights and obligations arising from the Agreement between the Promoter and the Company.

2. Legal Obligations. The Company is required to disclose or process data if requested by law.

3. Legitimate Interests. When data processing is necessary for the legitimate interests of the Company or a third party, as long as it does not violate the rights and interests of the promoter Consent.

4. Consent.
   Personal Data processing can only be carried out based on your Consent. However, such Consent may be revoked at any time and the revocation does not apply retroactively and does not affect the validity of the processing that has been carried out prior to the revocation and does not remove the Company's authority to continue processing Personal Data based on other valid legal bases.

The Company uses your Personal Data only for the purposes described in the Company's Privacy Notice and only to the extent necessary. If you refuse to provide certain Personal Data, you may not be able to use some of our services. The Company will retain Personal Data for as long as it is necessary to provide the services. Such Personal Data will be destroyed immediately when it is no longer needed by the company in accordance with the applicable procedures for the destruction of Personal Data.

How Maquira Collects Data

While you interact with the Platform, the Company may obtain Personal Data from various sources. Some data comes directly from you when you create an account, fill out a distributor form, place an order, communicate through customer service, or submit supporting documents required for the identity verification process. In addition, some data is collected automatically when you use the Platform, such as your IP address, device type, application usage data, cookies, or search preferences. We may also receive information from third parties that have a working relationship with Maquira, such as payment service providers, logistics partners, or data storage technology providers.

Information Collected by The Company

The Company may collect Personal Data directly from users, through the use of the Platform or from other legitimate sources. Personal Data as referred to includes but is not limited to:

1. Identity Data, which includes name, email address, ID card/passport number, Tax Identification Number, place and date of birth, residential address, telephone number, email, and identity photo

2. Account Data includes username and password, login data, account activity, and personal identity uploaded by the user

3. Contact and Communication Data includes chat history with customer service, telephone conversation recordings (if necessary for service purposes), requests, or support forms.

4. Transaction and Financial Data includes product purchase records, payment history, income amount (including bonuses and commissions), credit or debit card numbers entered to make payments, bank account information provided for the distribution of commissions and/or bonuses, and distributor commission and/or bonus amounts.

5. Distribution and Business Activity Data includes recruitment history, network structure, sales performance data, and product order data.

6. Device and Technology Data includes IP addresses, browser device types, cookies, other tracking technologies, and activity logs.

If you do not provide and/or fail to provide certain Personal Data when requested by the company, the company may delay and/or cancel its products and services to you, execute agreements with you, and be late in complying with the company's legal obligations. Some of the Personal Data requested by the Company from you is mandatory in relation to the provision of products and services to Promoters or consumers. If a Promoter chooses not to provide such Personal Data to the Company, the Company will not be able to provide products and services to you. This gives the Company the right to cancel any actions and/or agreements made with you as a promoter and/or consumer.

Personal Data used and disclosed by the Company is solely for the purpose of provision, including the purposes mentioned in Maquira's Policies and Procedures, unless the Promoter and/or is required by law.

Direct Marketing Communication

The Company may send direct marketing communications to Promoters, including information about products, promotions, membership programs, and other special offers relevant to your preferences. Such communications may be delivered through various channels, such as email, SMS, app notifications, or other electronic media, as long as this is done directly by the promoter to prospective promoters and/or consumers.

You have the right to choose whether to accept or decline such marketing communications. If you decide to stop receiving marketing messages from the Company, you can use the unsubscribe feature available in each message, change your account preferences, or contact official customer service. Stopping the receipt of marketing messages will not affect the delivery of important information related to transactions, services, or policy updates that are still necessary for the operational purposes of the platform.

Who Is Your Personal Data Shared With?

The Company uses your Personal Data to ensure that all services run smoothly, securely, and in accordance with applicable laws and regulations regarding Personal data. With your Consent, the Company may share your Personal Data with:

• Other entities within the Company, namely employee management and other companies affiliated with Maquira, both domestically and abroad, that need to access your personal data in order to carry out their responsibilities.

• Sponsors and upline business leaders who may need access to the personal information of their downline partners to monitor sales activities and development within their personal sales distribution channels.

• Third parties that assist the Company in delivering products to you, such as logistics companies and/or payment service providers.

• Third parties that assist the Company in conducting its business (agents, suppliers, company administrators, IT, printing, marketing, web equipment, or other services affiliated with the Company).

• Professional consultants including lawyers, banks, auditors, accountants, and companies that provide banking, legal, security, insurance, and accounting consulting services.

• Third parties that assist the Company in events, trips, or vendors appointed by the Company.

• Third parties that assist the Company in collecting feedback surveys from promoters.

• Government agencies and regulators, as well as other parties that require reporting of Company activities under certain circumstances, and

• Law enforcement agencies and regulatory bodies to comply with legal obligations.

In addition, the Company may send you information related to products, promotions, or policy updates relevant to your activities. You always have the right to choose whether to receive such communications or to opt out. Personal Data processing is also carried out to fulfill legal obligations, prevent misuse, manage disputes, and ensure operational activities comply with applicable regulations.

How and Why is Your Data Shared with Third Parties?

The Company does not sell Personal Data to any party. However, in carrying out our services, we collaborate with a number of third parties who require limited access to data to carry out certain operational tasks. For example, payment service providers for processing transactions, logistics partners for product delivery, or technology service providers for storing and securing databases. In the context of distributor membership, certain portions of data may be accessed by uplines or other partners with whom you have a direct network relationship, to the extent necessary to support your business activities and does not include sensitive data such as personal financial information. If data storage is carried out via servers outside Indonesia, the Company ensures that any data transfer abroad complies with data protection principles that provide a level of security no less than the provisions applicable in Indonesia.

Personal Data Protection

The security of your data is our priority. The Company implements technical and organizational measures to maintain the confidentiality of Personal Data, including the use of encryption, network security systems, internal access restrictions, and regular audits. Access to Personal Data is only granted to parties who need it to perform their duties, and all processing is carried out in accordance with applicable industry standards. Your data will be stored for as long as your account is active or as long as it is necessary to fulfill operational interests and legal obligations. After this period ends, the data will be deleted, anonymized, or further processed in accordance with Company policy.

Promoter's Rights as Data Owner

As the Owner of Personal Data, you have the right to access your data, request corrections to inaccurate data, withdraw certain consents, restrict processing, request data deletion, obtain data in a portable format, and object to automated processing. You also have the right to file a complaint if there is valid evidence that the processing of Personal Data does not comply with applicable laws. To exercise your rights, you can send an official request to the Company, specifying the type of request, such as a request for access, correction, update, or change of certain information. Once the request is received, the Company will verify your identity to ensure that changes or access are only granted to the rightful and legitimate data owner.

The Company will process each request within a reasonable period of time in accordance with applicable laws and regulations. Under certain circumstances, the Company may request additional information to expedite the verification process or to comply with applicable legal requirements.

If a request cannot be fulfilled for legal or operational reasons, the Company will provide a notification accompanied by an explanation of the basis for the rejection. You also have the right to ask questions or raise objections if you feel that your request has not been handled properly and professionally. To submit a request for access or correction of information, you can contact the company through the official channels available on the Maquira platform.

Data on Children Under 18 Years of Age

This Platform is not intended for children under the age of 18 (eighteen). If the company knows and/or discovers that personal data of children under that age has been collected without the consent of a parent or guardian, the company will take steps to delete or deactivate the account in question.

Business Transfer

Under certain circumstances, the Company may undertake a merger, acquisition, sale of assets, restructuring, or other form of change in ownership or corporate action. In the event of such corporate action, user Personal Data may become part of the assets transferred to the successor entity or party taking over the Company's operations. The Company will ensure that any entity receiving Personal Data has a legal obligation to respect the protection and security of Personal Data in accordance with this policy and applicable laws and regulations. If required by law, the Company will notify the Promoter before Personal Data is transferred to another party.

Cross-Border Transfers

The Company may process or store your Personal Data outside the territory of the Republic of Indonesia, including on servers or cloud service providers located in other countries. This cross-border transfer is carried out to support the smooth operation of the system, improve security, and provide more efficient services to users.

In conducting such transfers, the Company ensures that the destination country or recipient has data protection standards that are equivalent to or higher than the provisions of the Personal Data Protection Law applicable in the jurisdiction of the Republic of Indonesia. If these standards are not met, the Company will implement additional protections through contractual agreements or other legally recognized measures. By using the platform, you understand and agree that Personal Data may be transferred and processed in other jurisdictions as required for the Company's operational needs.

Use of Cookies and Tracking Technologies

Maquira uses cookies and other tracking technologies to help improve performance and user experience on the Platform. These technologies allow us to understand your preferences, save settings, analyze usage patterns, and provide more relevant content. You can manage or disable cookies through your browser settings, although this may affect some service functionality.

Changes to The Privacy Policy

This Privacy Policy may be updated from time to time to reflect changes in the law, internal policies, and/or service improvements. Changes will be announced on the platform, and your continued use after the changes have been implemented constitutes your acceptance of the latest version of this Policy.

Language Used

This Privacy Policy is written in Bahasa Indonesia and English. Both language versions have the same legal standing and are intended to provide consistent understanding to all Users, both domestic and international. If there are differences in interpretation or inconsistencies between the two language versions, the Bahasa Indonesia version shall prevail to the extent that it does not conflict with applicable law.

How to Contact Maquira

If you have any questions, complaints, or requests regarding the processing of Personal Data, you can contact the company through:

Email: support@maquira.com