Privacy Policy

Harsono Strategic Consulting (HSC) ("HSC Employee" or "Us") really respects matters relating to the protection of your privacy. Therefore, we compiled this Privacy Policy to explain to you how we obtain, collect, process, analyze, use, store, display, publish, transmit, disseminate, delete and destroy your Personal Data that is given to us or collected by us, both at the time of downloading, registering, accessing the website, and using HR administration services on HSC Employee ("Application"), unless provided for in a separate privacy policy.

You declare that your Personal Data is true and valid data, and you give us your consent to obtain, collect, process, analyze, store, display, publish, transmit, distribute, delete and destroy in accordance with this Privacy Policy and applicable laws and regulations. We hope you read this Privacy Policy carefully to ensure that you understand how your data is processed.

By using the HSC Employee application, it means that you acknowledge that you have read, understood and agreed to all the provisions contained in this Privacy Policy, which is an integral part of the HSC Employee Terms and Conditions.

1. Personal Data

"Personal Data" is any data, information, and/or information in any form that can identify yourself, which from time to time you convey to us or that you include or convey in, on, and/or through the application which concerns information regarding your personality, which includes, among others:

• Your full name
• Employee code
• Job title and position
• Electronic mail address (e-mail)
• Mobile / mobile phone number
• Device information (including but not limited to: IP address, location information, your device data, the IMEI number, device name, the name of the application that has been attached to your device)
• Location data (GPS coordinates) for attendance purposes
• Data relating to information about your HR administration activities on the HSC Employee application, including but not limited to: attendance records, leave requests, permission requests, timesheet data, and other HR-related transactions
• Other data classified as personal data

2. Accuracy of Personal Data

We need your Personal Data, one of which is to be able to process HR administration transactions. Therefore, the Personal Data that you provide to us must be as accurate as possible and not misleading. You must update and notify us if there are changes to your Personal Data, such as changes in telephone numbers, electronic mail addresses (e-mails), to changes in job positions along with the location of the department/unit where you are employed.

You hereby release us from any claims, lawsuits, compensation, and/or claims in connection with the failure of processing HR administration transactions on the HSC Employee application caused by the inaccuracy of the Personal Data that you provide to us.

In certain circumstances, you may provide Personal Data relating to other people (such as your family members). In such circumstances, you represent and warrant that you have the authority and consent from the owner of the Personal Data to provide us with their Personal Data for use in accordance with the purposes described in this Privacy Policy.

3. Collection of Personal Data

The provision of your Personal Data is voluntary. However, if you do not provide us with your personal data, we will not be able to process your personal data for the purposes described below, and may cause us to be unable to provide HR administration services that facilitate your work activities, including attendance management, leave requests, and other HR services.

We will collect your Personal Data when you create or update the data or at other times as we ask you if needed from time to time.

We will collect your Personal Data every time you access the HSC Employee Application or perform HR administration activities such as attendance recording, leave requests, permission requests, or other HR-related transactions.

4. Location Data and GPS Usage

5. Use of Personal Data

We will process, analyze, and/or use your Personal Data for the following purposes as well as other purposes permitted by applicable laws and regulations:

1. Identify and register you as a user of the HSC Employee Application and verify with the OTP (One Time Password) when you log in to the HSC Employee application, deactivate or manage your account.
2. Allows us to provide the HR administration services you have requested, including but not limited to: attendance management, leave requests, permission requests, timesheet recording, and other HR-related services.
3. Prevent, detect, investigate and resolve actions that are criminal, prohibited, illegal, illegitimate or fraudulent, which may occur in the use of the HSC Employee application (including but not limited to fraud, embezzlement, theft and attendance manipulation).
4. Develop, add and provide HR services and features to meet your needs.
5. Conducting research on demographic data of HSC Employee application users for service improvement.
6. Using your mobile device location services to verify attendance at authorized work locations and ensure accurate attendance records.
7. Develop, improve, and provide our services, the HSC Employee application, and features in the HSC Employee application.
8. Delivery of information that we consider useful to you including information about HR services from us after you give us your consent that you do not mind being contacted about our services.
9. Internal administrative purposes, such as; audits, data analysis, records in the database, payroll processing, and HR reporting.
10. Communicate with you regarding all matters regarding HSC Employee Application, Our HR services, and/or features thereof.
11. Maintain the safety, security, and continuity of the HSC Employee Application, Our services, and/or the features thereof.

6. Disclosures to Third Parties

For the purpose of developing, improving, protecting, or maintaining the HSC Employee Application, and/or our other services, we are sometimes required to display, publish, send and/or disseminate Personal Data to third parties. You hereby declare that you have given our consent, permission and authority to announce, send, and/or disseminate and provide access to Personal Data to third parties for the purposes referred to in paragraph 5 above. For the avoidance of doubt, the third parties referred to in this paragraph may include, but are not limited to:

1. Third Parties that are our affiliated companies for or in connection with purposes related to providing HSC Employee Applications, business management and other HR administration activities.
2. Government authorities or institutions if (a) is required or ordered by applicable laws and regulations (including but not limited to responding to questions related to regulations, investigations or guidelines, or complying with filing and reporting requirements or conditions based on statutory regulations that applies) and/or (b) there is a legal process related to Us.
3. Third parties if there are company transactions, such as: formation of joint ventures, sales of subsidiaries or divisions, mergers, consolidations, acquisitions, asset sales, or liquidation.
4. Other third parties (including agents, vendors, suppliers, contractors, partners and other parties who provide services to us or you, perform tasks on behalf of us or parties with whom we have commercial cooperation) for or in connection with the purposes in which the third party is involved or the purpose of our cooperation with these third parties (depending on the circumstances), which may include allowing the third party to introduce or offer HR services or products to you or carry out other activities including marketing, research, analysis and development of these third party products (depending on the circumstances).

In connection with the implementation of services in the HSC Employee application, we hereby declare that Harsono Strategic Consulting (HSC) will and can send, deliver and/or provide your Personal Data to other parties with whom HSC cooperates (as relevant), especially in order to be able to forward your requests for the support services you want to other support service providers. In this case, other parties who receive your Personal Data will be subject to the same obligations regarding the submission and use of data that apply to Harsono Strategic Consulting (HSC).

Regarding obtaining, collecting, processing, analyzing, using, storing, displaying, announcing, sending, disseminating, deleting and destroying your Personal Data in the implementation of HR administration services in the HSC Employee application, we ensure that Harsono Strategic Consulting (HSC) will do the same or commensurate with what we do in accordance with this Privacy Policy.

7. Links to Third Party Sites

HSC Employee applications may contain links to third party sites. We are not responsible for the collection, collection, processing, analysis, use, storage, display, announcement, transmission, distribution, deletion and destruction of your Personal Data by these third parties. If you provide information directly to the site, the privacy policy and terms of service on that site will apply, and we are not responsible for the information processing activities or privacy policy of that site.

8. Data Storage and Security

We ensure that your data collected and/or collected by us will be stored securely in accordance with applicable laws and regulations in Indonesia. We will retain your data for as long as necessary to fulfill the purposes described in this Privacy Policy.

We will stop storing, deleting and/or destroying Personal Data as soon as it is deemed that the purpose for collecting Personal Data is no longer required and permitted by the laws and regulations in force in Indonesia;

Your Personal Data may be stored, transferred or processed by third party service providers. We will make reasonable efforts to ensure that these third parties protect Personal Data that is commensurate with our commitments in accordance with this Privacy Policy.

9. Unauthorized Access

We are responsible for the Personal Data that we collect from you, but please note that you are also responsible for maintaining the confidentiality of your Personal Data by not allowing third parties to access your Personal Data without your consent and knowledge. In this connection, we are not responsible for the misuse of your account, password and/or PIN that you create and use to access your Personal Data wherever you store your Personal Data, including your account, password and/or PIN to access or login to the HSC Employee application. You must notify us if you believe that your HSC Employee application password and/or PIN has been misused by a third party.

10. Intellectual Property Rights

1. The entire HSC Employee application and its supporting systems including but not limited to all: (a) layout, design and appearance of HSC Employee application contained in or displayed on the HSC Employee application media; (b) logos, photos, images, names, brands, words, letters, numbers, writings, and color arrangements contained in the HSC Employee Application; and (c) the combination of the elements referred to in letters (a) and (b), is fully our Intellectual Property Rights and no other party also owns the rights to the Application or the layout, design and appearance of the Application.
2. You are not permitted from time to time to (i) copy, modify, adapt, translate, create derivative works from, distribute, sell, transfer, publicly display, reproduce, transmit, transfer, broadcast, decipher or disassemble any part from or in any other way exploiting the HSC Employee Application (including the support system and services therein) licensed to you, except as permitted in these Terms and Conditions, (ii) license, sub-license, sell, resell, transfer, transfer, distribute or exploit commercially or make available to third parties and/or software in a manner; (iii) publish, distribute or reproduce in any way the copyrighted material, trademarks, or other information we have without obtaining prior approval from us or the rights owner who license their rights to us, (iv) deleting any copyright, trademark or other proprietary notices contained in the HSC Employee Application, (v) reverse engineer or access the HSC Employee Application and/or its supporting systems to (a) build a competitive product or service, (b) build a product with using ideas, features, functions or similar graphics, or (c) copying ideas, features, functions or graphics, (vi) launching automated programs or scripts, including, but not limited to, web crawlers, web robots, web indexers, bots, viruses, worms or other similar applications and any program that may make multiple server requests per second, create heavy loads or hinder the operation and/or performance of the HSC Employee Application, (vii) using robots, spiders, site search/retrieval applications, or other manual or automated tools or processes to retrieve, index, "mine data" (data mine), or in any way reproduce or circumvent navigation or presentation structures of the HSC Employee application and the contents contained therein.

11. Request for Access and Change of Personal Data

You can request access and/or request changes to your Personal Data, by contacting the Harsono Strategic Consulting (HSC) IT Team (by including supporting evidence)

We reserve the right to refuse your request to access and/or change your Personal Data for reasons justified under applicable laws and regulations.

12. Withdrawal of Approval

You have the right to ask us to stop using your Personal Data for the purpose of conducting HR administration activities. If you intend to ask us to stop using your Personal Data, you can contact HRD who will be referred to the Harsono Strategic Consulting (HSC) IT Team (by including supporting evidence).

In the event that this agreement is withdrawn, it may result in the termination of your access to HR administration services or our agreement with you, provided that all rights and obligations that arise thereafter must be fulfilled. After you convey your intention to withdraw your consent, we will notify you about the possible consequences, so you can decide whether you want to withdraw your consent or not.

This Privacy Policy is effective as of April 2026 and may be updated from time to time to reflect changes in our practices and applicable laws.