Definitions and Interpretation

For these Terms and Conditions, the terms below shall have the following meanings, unless the context otherwise requires:

1. User Account: An access identity created by the User/Promoter on the Platform, containing personal data, login credentials, preferences, and other information necessary to use the services. The Account serves as a means of authentication and authorization, and any activity conducted through it is deemed a valid action by the User/Promoter.

2. Personal Data: Data regarding an identified or identifiable individual, business entity, or legal entity, either on its own or in combination with other information, obtained through electronic or non-electronic systems.

3. Information: Descriptions, statements, ideas, and signs, including data, facts, and their explanations, that contain value, meaning, and messages, presented in various electronic or non-electronic formats.

4. Data Controller: Any individual, public body, or international organization acting alone or jointly in determining the purposes and exercising control over the processing of Personal Data.

5. Personal Data Protection: The overall effort to protect Personal Data throughout the data processing chain to ensure the rights of the data subject.

6. Company: Maquira, including all entities owned, controlled, or operated by Maquira, which is responsible for the provision, management, development, and operation of the Platform, services, products, content, and related business processes. This term also includes management, employees, representatives, consultants, and other parties acting lawfully on behalf of Maquira.

7. Processing: Any action taken with respect to Personal Data, including but not limited to collection, storage, use, alteration, deletion, and disclosure.

8. Promoter: An individual or legal entity that has been registered, verified, and approved by the Company as an independent member of the Company’s marketing or sales network, who is required to conduct their activities in accordance with applicable guidelines, codes of conduct, and laws and regulations.

9. Consumer: Any person who uses Goods and/or Services available to the public for personal or non-commercial purposes and not for resale.

10. Service Provider: Maquira, as the entity that owns and operates the https://maquira.com Platform and is responsible for managing digital services, including the website, applications, membership systems, and data centers for Users/Promoters.

Legal Basis and Purpose of Data Processing

The Company lawfully processes User/Promoter Personal Data based on one or more of the following legal bases:

1. Performance of a Contract: Processing is necessary to perform the rights and fulfill the obligations arising from the agreement or contractual relationship between the Promoter and the Company.

2. Legal Obligations: Processing is necessary to comply with legal obligations applicable to the Company, including but not limited to, the disclosure of data to authorized authorities when required by law.

3. Legitimate Interests: Processing is necessary for the legitimate interests of the Company or a third party, provided that such interests do not override the fundamental rights and interests of the User/Promoter that require Personal Data Protection.

4. Consent: Processing is carried out based on the explicit consent of the Promoter.

Consent and Withdrawal of Consent: Although processing may be based on consent, such consent may be withdrawn by the Promoter at any time. Withdrawal of Consent is not retroactive and will not affect the validity of Processing carried out prior to withdrawal. Withdrawal of Consent does not preclude the Company’s authority to continue processing Personal Data based on other lawful grounds as mentioned above.

Purpose and Data Retention: The Company will use Personal Data only for the purposes transparently described in the Company’s Privacy Policy and only to the extent necessary to achieve those purposes. If the User/Promoter refuses to provide certain mandatory Personal Data, the User/Promoter may not be able to use some or all of the services offered by the Platform. The Company will retain Personal Data for as long as necessary to provide services or comply with legal obligations. Personal Data will be destroyed immediately after it is no longer needed by the Company, in accordance with applicable personal data destruction procedures.

Sources and Methods of Collecting Personal Data

While the User/Promoter interacts with the Platform, the Company may obtain Personal Data from the following sources:

1. Data Provided Directly by Users/Promoters: The Company collects data that is directly and voluntarily submitted by Users/Promoters, including but not limited to: (i) creation of a User Account, including credentials and profile information; (ii) completion of distributor registration forms or product orders; (iii) communication through customer service or the Company’s official communication channels; (iv) submission of supporting documents required for the identity verification (KYC) process or other compliance purposes.

2. Automatically Collected Data: Data is collected automatically through the use of the Platform, including but not limited to (i) Internet Protocol (IP) addresses; (ii) information regarding the type of device used; (iii) application usage data and browsing activity; (iv) data collected through cookies or similar tracking technologies for the purposes of analysis or preference customization.

3. Data Received from Third Parties: the company may receive Personal Data from third parties with whom Maquira has a legitimate business relationship, including but not limited to (i) payment service providers; (ii) logistics and shipping partners; (iii) technology service providers, including data storage providers.

Types of Personal Data Collected and Data Provision Obligations

The Company is entitled to collect and process Personal Data of Users/Promoters obtained directly from Users/Promoters, through the use of the Platform, or from other legitimate sources, which include but are not limited to the following categories:

1. Identity Data: Full name, email address, ID/Passport number, Tax Identification Number (TIN), place and date of birth, residential address, phone number, and a copy of an identity document.

2. Account Data: username, password, login data, account activity history, and personal identification uploaded for authentication purposes.

3. Contact and Communication Data: Conversation history with customer service, telephone conversation recordings (if relevant to service quality or compliance), and support requests or forms.

4. Transaction and Financial Data: Product purchase records, payment history, income information (including commissions and bonuses), credit or debit card details entered for payment processing, bank account information for the disbursement of commissions and/or bonuses, and the amount of commissions and/or bonuses received.

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

6. Device and Technology Data: IP address, device type, browser, cookie data and other tracking technologies, and Platform usage activity logs.

The Company may determine that certain Personal Data is mandatory for the provision of products and services to Promoters or Consumers. A User’s/Promoter’s failure to provide such mandatory Personal Data may result in delays and/or cancellation of services, termination of agreements, and/or the Company’s inability to comply with applicable legal obligations. The Company reserves the right to cancel any action and/or agreement entered into with the User/Promoter if the User/Promoter chooses not to provide such mandatory Personal Data. Personal Data will only be used and disclosed by the Company for the purpose of providing services and products, including purposes explicitly set forth in Maquira’s Policies and Procedures, unless required or permitted by applicable law.

Direct Marketing Communications and The Right to Opt Out

The Company reserves the right to use the User’s/Promoter’s Personal Data to send direct marketing communications, including product information, promotions, membership programs, and other special offers deemed relevant to the User’s/Promoter’s interests. Marketing communications may be delivered via various electronic channels, including email, short message service (SMS), and app notifications, provided this is done in accordance with applicable licensing terms and regulations. The Company’s delivery of marketing communications does not include marketing activities conducted directly by the Promoter to prospective Promoters and/or Consumers, which remain the Promoter’s sole responsibility. Users/Promoters have the right to choose whether to accept or decline such direct marketing communications (Opt-Out). The right to decline may be exercised through (i) using the unsubscribe feature available in every marketing message sent; (ii) changing account preferences on the Platform; (iii) contacting the Company’s official customer service.

The decision to stop receiving marketing messages will not affect the delivery of important information regarding transactions, services, or policy updates that are mandatory and necessary for the Platform’s operational continuity or the fulfillment of the agreement.

Disclosure of Personal Data to Third Parties

The Company uses Users’/Promoters’ Personal Data solely to ensure all services operate properly, securely, and in compliance with applicable laws and regulations, including personal data protection regulations. With the User’s/Promoter’s consent, the Company may disclose Personal Data to the following categories of recipients: (i) Maquira’s management, employees, and affiliated companies (both domestic and international) who require access to the data to fulfill their responsibilities; (ii) sponsors and upline business leaders within the distribution network who require limited access to downline partner information to monitor sales activities, performance, and the development of their personal networks; (iii) third parties assisting the Company in delivering products, such as logistics companies, and/or payment service providers to process transactions; (iv) third parties that assist the Company in conducting business, including agents, suppliers, and providers of administrative, IT, marketing, web infrastructure, or other services affiliated with the Company; (v) professionals including attorneys, banks, auditors, accountants, and firms providing legal, financial, security, insurance, and banking consulting services; (vi) third parties appointed by the Company to assist in organizing events or trips; (vii) third parties that assist the Company in collecting surveys and feedback from Promoters.

Mandatory Disclosure and Legal Compliance. The Company may also process and disclose Personal Data without explicit consent for (i) government agencies and regulators that require reporting of the Company’s activities under certain circumstances; (ii) law enforcement agencies and regulatory bodies to fulfill legal obligations, prevent misuse, manage disputes, and ensure the Company’s operational activities comply with applicable regulations.

Sharing and Transfer of Personal Data

The Company confirms that Users’/Promoters’ Personal Data will not be sold to any party. The Company may share Personal Data with third parties contracted by the Company, but only to the extent strictly necessary for the performance of operational, security, and compliance duties under applicable laws and regulations. Recipients of Personal Data include (i) payment service providers to process financial transactions; (ii) logistics partners for product delivery; (iii) technology service providers for database storage and security. Within the Promoter’s membership framework, certain Personal Data that does not include sensitive data (such as personal financial information) may be accessed on a limited basis by uplines or other partners who have a direct network relationship with the User/Promoter, to the extent such access is necessary to support and monitor the relevant Promoter’s business activities. If Personal Data is stored or processed via servers outside the territory of the Republic of Indonesia, the Company guarantees that any cross-border data transfer will comply with data protection principles and provide a level of security no less than that required under the Personal Data Protection Act 2012 (Singapore).

Personal Data Security and Retention

The Company prioritizes the security of Users’/Promoters’ Personal Data. It implements adequate technical and organizational security measures in accordance with applicable industry standards to safeguard the confidentiality, integrity, and availability of Personal Data. These security measures include, but are not limited to, the use of encryption, advanced network security systems, and periodic security audits. Internal access to Personal Data is strictly limited to personnel who require such access to perform their operational duties and responsibilities.

Personal Data will be retained for as long as the User/Promoter Account remains active or for a period reasonably necessary to fulfill the Company’s legitimate operational interests and legal obligations. Once this retention period expires, the Company will take the necessary steps to securely delete Personal Data, anonymize the data (where permitted), or further process it in accordance with the Company’s internal policies and applicable laws and regulations.

Rights of Data Subjects

As the owner of Personal Data, the Promoter/User has legally recognized rights, including but not limited to the right to (i) access Personal Data stored by the Company; (ii) request the rectification or correction of inaccurate or incomplete Personal Data; (iii) withdraw consent for the processing of specific personal data; (iv) request the restriction of processing and/or the erasure of personal data, subject to applicable legal provisions; (v) receive Personal Data in a structured, commonly used, and machine-readable format (data portability); (vi) object to automated processing; (vii) file a formal complaint if there is valid evidence that the processing of Personal Data does not comply with applicable laws and regulations.

Users/Promoters must submit a formal request to the Company through the communication channels available on the Maquira Platform, specifying the type of right being exercised (e.g., access, correction, or deletion). The Company must conduct strict identity verification of the requester to ensure that access or changes are granted only to the legitimate Data Subject. The Company reserves the right to request additional information to expedite the verification process and ensure legal compliance. The Company will process every valid request within a reasonable timeframe in accordance with applicable data protection laws and regulations.

If a request cannot be fulfilled due to valid legal or operational reasons, the Company will provide an official notification accompanied by a written explanation regarding the basis for the refusal. Users/Promoters have the right to file an objection if they feel that the request was not handled appropriately and professionally.

Age Restrictions and Child Data Protection

This Platform and the Services are exclusively intended for individuals who are at least 18 (eighteen) years of age or are considered adults under the applicable laws of the relevant jurisdiction. The Company does not intentionally collect, process, or store personal data from individuals under the age of 18. By accessing or using the Services, Users represent and warrant that they meet the legal age requirements. Use of the Services by anyone under the age of 18 constitutes a material breach of these Terms and Conditions.

In the event the Company identifies, either through internal verification mechanisms or third-party reports, that a Child’s personal data has been collected without verifiable evidence of valid consent from a parent or guardian, the Company will take the following actions: (i) Immediate suspension by deactivating or suspending the associated account without prior notice; (ii) Permanent deletion of such personal information from the Company’s database, unless the retention of such data is required by applicable law for regulatory compliance purposes; (iii) Parents/Guardians who discover that their child has provided personal data to the Company without permission may contact the Company’s customer support service to request immediate deletion.

Business Transfers and Corporate Actions

Corporate Restructuring. You acknowledge and agree that in the event the Company engages in a corporate action, including but not limited to, a merger, consolidation, acquisition, restructuring, reorganization, asset sale, or in the event of liquidation/bankruptcy (collectively referred to as “Corporate Actions”), the User’s Personal Data may be transferred, sold, or assigned as part of the Company’s business assets to a successor entity or acquiring party (“Third-Party Recipient”).

Obligations of the Successor Entity. The Company guarantees that any Third-Party Recipient receiving a transfer of Personal Data is legally obligated to (i) comply with and respect standards of protection and security for Personal Data that are equivalent to or higher than those outlined in this Privacy Policy; (ii) process Personal Data only in accordance with the original purpose for which the data was collected, unless new consent is obtained from the User.

Notification and Transparency. In accordance with applicable laws and regulations, the Company will provide written notice to the User within a specified timeframe before the transfer of Personal Data. Such notice will include the identity of the recipient and the effective date of the transfer to ensure full transparency.

Cross-Border Transfer of Personal Data

The User hereby acknowledges and explicitly consents to the Company transferring, storing, and processing Personal Data outside the legal jurisdiction of the Republic of Singapore. This includes, but is not limited to, the use of data centers, servers, or third-party cloud service providers located in other jurisdictions to ensure service availability, data redundancy, and system security optimization. In the event of cross-border data transfers, the Company is committed to ensuring that Personal Data remains protected by verifying that the destination country or data recipient has data protection regulations that are equivalent to or provide a level of protection comparable to Singapore’s Personal Data Protection Act (PDPA). In cases where the recipient’s jurisdiction lacks equivalent protection standards, the Company will implement adequate safeguards through Standard Contractual Clauses, Binding Corporate Rules, or other internationally recognized legal mechanisms to ensure data integrity and confidentiality.

All cross-border data transfers will be conducted using high-level encryption protocols and strict technical and organizational measures to prevent unauthorized access during transmission. By continuing to use this Platform and these Services, Users are deemed to understand and accept the risks inherent in international data transfers and voluntarily consent to the processing of such data for contract performance and the Company’s service operations.

Cookies and Similar Tracking Technologies

The Company uses cookies, web beacons, pixels, SDKs, and similar tracking technologies (collectively referred to as "Tracking Technologies") to automatically collect information regarding your use of the Platform. This use is intended to ensure system stability, enhance transaction security, and optimize the operational experience for Users. The Tracking Technologies used are categorized as (i) Essential Cookies (Strictly Necessary), which are required for the Platform to function, including for user authentication, fraud detection, and secure transaction processing. Without these cookies, core services cannot be provided; (ii) Performance and Analytics Cookies allow the Company to count visits and traffic sources to measure and improve Platform performance through aggregated data analysis; (iii) Functionality Cookies are used to remember your preferences (such as language or region) and provide personalized features; (iv) Marketing/Third-Party Cookies are used by our advertising or analytics partners to build a profile of your interests and display relevant content or ads on other sites.

When you first access the Platform, you will be given the option to provide explicit consent for the use of non-essential Tracking Technologies. You have the right to manage, limit, or disable Tracking Technologies through your browser settings or via the cookie preference panel available on our Platform. You acknowledge that if you refuse or delete certain Tracking Technologies (particularly Essential Cookies), some features of the Platform, including but not limited to the checkout process or access to secure areas, may not function optimally or may be inaccessible altogether.

Amendments and Changes to The Privacy Policy

The Company reserves the right to review, amend, modify, or update the terms of this Privacy Policy at any time at the Company’s sole discretion. These changes are made to ensure compliance with evolving legal regulations, align with industry practices, and enhance the functionality and security of the Services. In the event of material changes (changes that significantly impact Users’ rights and obligations), the Company will make reasonable efforts to notify Users via (i) a prominent announcement on the Platform interface; and/or a written notification sent to the email address registered in our system.

Any changes will take effect immediately upon publication of the latest version on the Platform, or on another effective date specifically stated in such notice. Users are responsible for periodically checking this page to stay informed of the latest updates. Continued access to or use of the Service after the effective date of the changes will be deemed to constitute the User’s valid, binding, and irrevocable acceptance and consent to the latest version of this Privacy Policy. If the User does not agree to the changes or updates made, the sole legal recourse available to the User is to cease using the Platform and close the associated account before such changes take effect.

Governing Language

This Privacy Policy is drafted and published in both Indonesian and English versions. Both versions are intended to have identical substance and provide transparency for all Users. In the event of any inconsistency, contradiction, or difference in interpretation between the Indonesian version and the English version, the English version shall prevail and govern to the extent permitted by applicable law.

The Parties hereby agree that in the event of a dispute or legal proceeding, the interpretation of this Privacy Policy shall refer to the legal terminology that most closely approximates the original intent in the English version. Unless otherwise required by law, any translation is provided solely for the convenience of the User, and no party may rely on an inaccurate translation as a basis for a legal claim against the Company.

Communication and Contact Information for Data Protection

To ensure compliance with this policy and applicable laws and regulations, Maquira has appointed a dedicated team or Data Protection Officer (DPO) responsible for overseeing and managing data privacy on the Platform. Users may submit questions, objections, reports of violations, or formal requests regarding their personal data rights (including but not limited to the right to access, correct, or delete data) via email: support@maquira.com with the subject line "Personal Data Request - [User Name]" to expedite the identification process.

To protect the security and confidentiality of Personal Data, the Company reserves the right to conduct strict identity verification procedures on Users before processing or providing any information related to the submitted request. The Company will not process requests from third parties without valid and verifiable proof of power of attorney. The Company is committed to responding to every request or complaint promptly, with a target timeframe of no more than 30 (thirty) calendar days from the receipt of a complete request, or in accordance with the timeframe required by applicable law in the relevant jurisdiction.