Privacy Policy
last update: January 11, 2024
PT Atmapurwa Global Teknologi ("Soulmi", "we", "us" or "our") is the Controller for the processing implemented through this website accessible at https://soulmi.com/ (the "Services"). This notice describes how PT Atmapurwa Global Teknologi processes Personal Data to provide the Services (duly incorporated in the Republic of Indonesia, having its address at Jl. Telekomunikasi No.1, Sukapura, Kec. Dayeuhkolot, Kabupaten Bandung, Jawa Barat, Indonesia and registered with the Indonesia Business Registry under the number 3112240001029).
The Services are an online chat application that uses artificial intelligence algorithms to generate virtual and fictional characters (the "AI Companions") and can also generate images and messages, so that you can chat with the AI Companions. Parts of the Services offered may require you to create a user account. For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services.
1. Definitions
As we are committed to respect your privacy, such Services will always be provided in accordance with the most relevant legal basis.
By using the Services, you agree that you have read and understood our Privacy Policy.
All capitalized terms not otherwise defined in this Privacy Policy shall have the following meaning:
- "Content": the information that you will provide us with, so that we can register you as a User and the information you will upload on our Services, such information shall include your Personal Data and the discussions with the AI Companions;
- "Consent": any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to you;
- Controller": the natural or legal person, alone or jointly with others, determines the purposes and means of the Processing of Personal Data and for the purposes of the Services, PT Atmapurwa Global Teknologi;
- "Performance of our Services": the actions necessary for us to provide our Services notably further to your Subscription;
- "Personal Data": any information relating to an identified or identifiable natural, person, directly or indirectly ("Data Subject"), such as your name, address, marital status, date of birth, gender, office location, position, company name, spoken languages, photos, your account number, your location data;
- "Processing": any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- "Subscription": an arrangement between PT Atmapurwa Global Teknologi and you to enable you to benefit from and / or use the Services;
- "User", "you" and "your": collectively a person that has visited or is using the Services;
- "Visitor": anyone who is browsing the Services without a valid Subscription;.
2. Purpose of Personal Data Processing
Purpose of the Processing | Categories of Personal Data | Legal basis |
---|---|---|
Account creation |
| Necessity for the performance of a contract. |
Account management |
| Our legitimate interest to address your queries. |
Provision of the Services
| Content data i.e:
| Necessity for the performance of a contract. |
Support of the Services |
| Our legitimate interest to address your queries. |
Provision of the Subscription payment Service
| Xendit
| Necessity for the performance of a contract. |
Direct Marketing
|
| Our legitimate interest to improve our Services (direct marketing by us for similar products and Services) or consent (third party marketing). |
Analytics other than through cookies or other tracking technologies |
| Consent |
Safety |
| Necessity to comply with legal obligations or, as the case maybe, necessity for the performance of the Service agreement (in case of breach of the T&Cs). |
Legal & Accounting
| Supporting data (as provided by you) such as contact data, payment data or credentials. | Necessity for compliance with legal obligations. |
Complying with court orders and exercises and/or defend our legal rights. | Supporting data (as provided by you) such as contact data, payment data or credentials. | Our legitimate interest to defend our rights. |
If you fail to provide your Personal Data, we may not be able to perform the Services pursuant to the Subscription. In this case, we may have to cancel the Service, provided that we will notify you if this is the case at the time.
3. Marketing
We may send you marketing about Services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you or in order to update you with information (such as commercial news) which we believe may be relevant to you. We may communicate this to you in a number of ways that you provided including by, telephone, email or other digital channels.
If you do not wish to receive marketing information from us, you can unsubscribe in any of the following ways:
a. clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us; or
b. contacting us using the contact details.
Please note that the opt-out of marketing communications will not affect the sending of communications related to Services themselves.
4. Third Party Marketing
We will get your express opt-in Consent before we share your Personal Data with any company outside PT Atmapurwa Global Teknologi for marketing purposes.
You can ask us or third parties to stop sending you direct marketing messages by electronic means at any time by logging into the Services, or third parties websites and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you by such third parties.
5. Sharing your Personal Data
Soulmi.com may share your information with:
a. service providers we work with to deliver the Services as follow:
- payment service providers;
- hosting service providers;
- email marketing tools providers; and
- affiliate partner tools.
b. our professional advisers where it is necessary for us to obtain their advice or assistance including lawyers, accountants, IT or public relations advisers ;
c. legal and regulatory authorities, as required by applicable laws and regulations; and our employees.
We will not disclose, sell, trade, or otherwise transfer your Personal Data to any third parties without your Consent where required or unless otherwise stated in this Privacy Policy.
If PT Atmapurwa Global Teknologi merges with, or is acquired by, another company or organization, or sells all or a portion of its assets, your Personal Data may be disclosed to our advisers and any prospective purchaser or any prospective purchaser's adviser and may be among the assets transferred. However, Personal Data will always remain subject to this Privacy Policy.
6. Retention Period
We retain your Personal Data for as long as your account is in existence or necessary to fulfill the purposes for which we collect it or as needed to provide you with the Services, except if required otherwise by law. However, when you terminate your account, we will still retain your Personal Data for a period of time. Usually, we will store your Personal Data for a period after you cease being a User of our Services, beginning at the date your account is closed.
Retention periods may be changed from time to time based on business or regulatory requirements.
We generally keep:
a. Personal Data relating to your account will be retained for the period necessary to fulfill the purposes for which it was collected. This may include fulfilling customer service needs, meeting legal obligations (including statutes of limitations), and resolving disputes. We strive to minimize data retention periods while ensuring we can meet these requirements;
b. The financial and transactional data seven years from their date of issuance (in accordance with our tax obligations); and
c. The marketing data until you withdraw your Consent or for a period of two years after your last interaction.
Our team remains available to take into account any (i) account closure and/or (ii) right of opposition to further marketing communications you would express
7. Personal Data of Minors
PT Atmapurwa Global Teknologi does not provide Services and collect Personal Data from anyone under 18 years of age or equivalent minimum age depending on jurisdiction. Our Services are intended for use only by adults who are 18 years of age and over. If we learn that we have been misled by an individual under 18, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible and block this User.
8. Third-party Links
The Services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the Privacy Policy of every website that can be accessed through the Services.
9. Contact Us
If you have concerns about how we are Processing your Personal Data, we ask that you please attempt to resolve any issues with us first. If you have any questions, concerns, or complaints regarding this Privacy Policy, or if you wish to exercise your rights related to your Personal Data, you can reach us at the following contact details.
Privacy Team
Email: atmapurwa9@gmail.com
Mailing Address: PT Atmapurwa Global Teknologi, Jl. Telekomunikasi No.1, Sukapura,
Kec. Dayeuhkolot, Kabupaten Bandung, Jawa Barat, Indonesia
Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Contact details: atmapurwa9@gmail.com
10. Data Security
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
11. Changes to the Privacy Notice and your duty to inform us of changes
We may revise this Privacy Policy from time to time to take account of our changes of practices or of new applicable data protection law. If we modify our Privacy Policy, we will post the revised version on the Services with an updated revision date. Where such changes are substantial, we will also notify you by other means prior to the changes taking effect, such as by sending you an email notification or through the Service. By continuing to use our Services thirty days after such revisions are in effect, you will be deemed to accept and agree to the revisions and to abide by them.