Privacy Policy

We value your trust and take the protection of your personal information very seriously. This document outlines the way in which we collect, hold, secure, use and share your personal information. We encourage you to read it, so that you are comfortable with what we do and can help us improve your experiences with us.

1. What is covered by this Privacy Policy?

This Privacy Policy outlines our personal information management practices, including how we collect, hold, secure, use and share your personal information. Specifically:

• The kinds of personal information we collect and hold.
• How we collect and hold it.
• The purposes for which we collect, hold and use it.
• How we secure it.
• How, and to whom, we share your personal information, including overseas, and why.
• Your right to access and correct it.
• How you may contact us if you wish to make a complaint or enquire about privacy matters.

There are some matters to which this policy does not apply. Please refer to Section 15 below.

2. What is privacy/personal information? 

The Bank acknowledges that in the course of providing the services hereunder, it may prepare or have access to data that is personally identifying information, of the employees, guests and customers or potential customers (“Personal Information”). Such Personal Information requires a higher standard of care and Almaluna agrees to use its best efforts to protect such Personal Information. All Personal Information in the possession of Almaluna shall be kept in a secure location. Almaluna shall control use of the Personal Information. Almaluna will comply with all privacy policies required. Almaluna agrees to take the required organized technical steps necessary to protect the Personal Information, including but not limited to training relevant employees regarding such Personal Information.

Almaluna shall use any Personal Information it prepares or receives from customers only to fulfil its obligations under this Agreement.

Almaluna agrees it will not share, rent, sell, or in any way transfer any Personal Information whatsoever to any third party for any reason without the specific written direction of the customers or brands, unless required by law, in which case Almaluna will provide with immediate notice of such request.

Any time we use the term “Personal Information” in this policy, we are referring to this definition of the term.

3. What kinds of personal information does Almaluna collect and hold, and how does Almaluna collect it?

We always want to provide you with the highest level of service, so we collect and hold personal information necessary for our business activities and to enable us to provide the information, goods or services you might be looking for. If we do not collect the information, we may not be able to provide these things. 

We collect your personal information directly from you when you activate or use our services, interact with us, either in person, over the telephone or electronically (e.g. via websites, apps, social media posts, chats, telephone, emails and/or SMS) or as otherwise required by law. For example: 

• Your contact details including your name, email addresses, telephone numbers, residential and delivery addresses;
• Your member number; or
• Anelectronic copy of the written communication or voice recording of the conversation (we always let you know when your conversations with us will be recorded).

Below are some examples of personal information we may collect from you and how we collect that information: 

When you register to participate in one of our loyalty programs or when you use your member card:

• Your contact details;
• Date of birth and gender;
• Payment card and transaction details;
• Information about purchases for which you earn loyalty points as well as your use of those loyalty points.

When you shop with us, including online, or browse our sites or apps:

• Your contact details and loyalty card number
• Information about your orders and purchases, including what, how, and when you buy from us, how you paid for purchases (including payment card details and transaction details);
• We may ask for your ID, such as your driver’s licence, if you purchase alcohol or tobacco or other forms of identification so that you can use certain serviceswe provide;
• Whether you have taken up or subscribed to any of our offerings such as clubs or loyalty programs, financial services products including insurance and credit cards or our apps;
• Information about your online browsing behaviour on our internet sites and apps, including promotions you activated, as well as items you have added to your carts;
• Information collected and held via our secure financial systems about the payment method  you use for your purchases from us;
• Like many websites, tracking technologies, such as “cookies”, are used to obtain certain types of information such as application activities, current location of your device, type and version of your browser, your device ID and other device metrics when you visit our websites, apps or our trusted partners’ websites or apps;
• Images and video that you have posted online to facilitate our service provision or sales promotion; and
• Information we collect via our apps on mobile devices or smart devices (e.g. smart watches), for example the current location of your device, type and version of your browser and, your device ID and other device metrics, as allowed by your device permissions.

When you contact us or we contact you to take part in competitions, promotions, testimonials, reviews, surveys, focus groups or make other enquiries:

• Your contact details and loyalty card number.
• Whether you activated the promotion.
• The content of online communications with you, including competitions, promotions, feedback, reviews, ratings, comments and images included on any of our websites, apps or social media pages or any of our other digital services.
• An electronic copy of the written communication or voice recording of the conversation.

When you visit us in person, including for events:

• Your contact details, your ID, and loyalty card number for third party such as pick up, home delivery or special orders;
• We may ask for your ID, such as your driver’s licence, if you purchase alcohol or tobacco;
• Cameras (including security and smart cameras) may record footage and other data which may identify you; or  
• Your contact details if security or team members are investigating whether you may have breached any store procedures or if you are injured in any one of our stores or are witness to an incident. 

Other sources:

From time to time we may also collect personal information about you from other sources to help us supplement our records, improve the personalisation of our service to you, manage our services, and detect fraud. 

4. Do I have to provide my name?

For many of our services, you generally have the option not to give us your name and can use a pseudonym if you prefer.  We may need your real name and a valid ID for specific purposes or where we are required to ask by law.

5. Can I provide someone else’s personal information to Almaluna ?

Yes, you may provide someone else’s personal information to us, for example, when you purchase a gift for others, place an order on someone else’s behalf, or when you open a Loyalty Program account on someone else’s behalf. You must have their consent beforehand and we may ask you to provide evidence of that consent. You should not provide someone else’s information if you don’t have their consent, or for malicious purposes.

6. Do you collect my sensitive information?

Some of our products and services may require us to collect your “sensitive information” (which is defined in the Privacy Act and is a subset of ‘personal information’) from you or from other sources. Sensitive information is only obtained with your consent or in certain limited permitted situations.

7. How does Almaluna secure my personal information?

Your personal information is important to us. We design our systems with your security and privacy in mind. Any personal information we hold is generally stored electronically in computers or cloud systems operated by us or by our service providers. We implement a range of information security measures and encryption protocols when we handle your personal information to protect it from unauthorised access, loss, misuse or wrongful alteration. 

We may collect information from your current device using cookies or other technologies, including your online browsers or apps to protect your account security. See Section 3 for examples of what kinds of information we may collect.  We use security measures such as physical and technical security access controls or other safeguards, information security technologies, policies, procedures and training programs to ensure the security of your personal information.

We protect your payment card details with encryption and hashing methods. Do not include your full card details when you communicate with us via email, SMS or chat messages. If we have to make a reference to your payment card number, we will only refer to the last four digits in any form of written communications.

8. For what purposes does Almaluna collect, hold and use my personal information? 

We primarily collect, hold and use your personal information to supply, promote and sell goods and services that you have requested, or which may be of interest to you, so that we can improve and personalise your experiences. This may also include the products and services of our suppliers and trusted partners.  EGL also collects, holds, and uses your personal information to meet legal requirements that EGL is required to follow. 

We may use your personal information for purposes which are incidental to the sale and promotion of our goods and services, or for other purposes which are within your reasonable expectation or permitted by law.  In addition, your personal information may be used for the following purposes:

• Personalisation : To identify your preferences, to recommend features, products, and services that may be of interest to you, and to personalise your experience with EGL.
• Communication : To send you offers and other communications that may be of interest to you. 
• Create and maintain your loyalty account : To capture and reward your shopping behaviour, and to provide customer support if needed.
• Investigation : To assist in responding to your complaints or enquiries and to undertake investigations.
• Fraud detection and security : To verify your identity and to detect fraud activities. We may conduct auditing and monitoring of transactions and financial engagement.
• Improve our services and customer experience : To analyse performance, improve our systems and improve the usability, functionality and effectiveness of our services.
• Analysis : To analyse your personal information in an anonymised and combined way when we communicate with you about your preferences and interaction with Almaluna; for example weekly personalised specials.
• Legal Requirements : To comply with legal requirements including licensing and reporting obligations, Almaluna must collect and hold your personal information.

9. Who does Almaluna share my personal information with and why?

Your personal information is important to us and we are very focused on making sure it stays safe. We use data, including personal information in some cases, to understand the preferences and shopping patterns of our customers and to produce other insights. 

In most cases, we employ techniques such as grouping, combining and anonymising, so that we don’t need to use your personal information to understand those preferences or patterns, or to produce insights. We may also share anonymised preferences and insights with our suppliers, partners and service providers to assist with the marketing of products and services, without revealing your personal information.  

There are limited circumstances when we do need to share or use your personal information, such as: 

• When you make a written request to share your information with a third party;
• To related companies;
• For fraud detection and security protection;
• When legally required, including assisting with police investigations and where required by law enforcement agencies; and
• With third parties, such as partners, suppliers, or service providers, when we need their assistance in our day-to-day business operations or so we can work with them to provide services to you.
• There are also limited circumstances in which we may share your personal information with third parties, such as:
• Financial services organisations or specialised service providers for fraud detection (when we process your payments);
• Print partners for direct mail and card fulfilment (when you register and order a loyalty card from us);

10. Marketing communications

When you register to hold an account or become a member of Almaluna or program, we may send you commercial electronic messages and tailored advertising if you agree to let us do so. We may send you these messages via various channels and media (including by email, SMS, phone and mail, or via advertising on certain websites and social media), but only where you have not opted out of receiving such electronic messages from Almaluna or program in that channel.  

You can opt out of commercial electronic messages by using the relevant unsubscribe facility for the Almaluna or program which sent the message.  The appropriate unsubscribe facility may depend on the subject of the message or the channel used to send the message.  Details on how to opt out of commercial electronic messages in relation to Almaluna or program are contained within the terms and conditions for the relevant brand or program.

11. Does Almaluna share personal information overseas?

Some of our service providers, including data storage and technology service providers, may be located or use locations outside of Indonesia. Where we share personal information overseas, we take steps to ensure that our service providers are obliged to protect this personal information in accordance with Indonesia legal requirements and that they are only permitted to use personal information for the purpose for which it is shared. Our service providers or their data storage servers may be located, and may store your personal information from time to time, in a number of countries.

We may share your personal information overseas for reasons including:

• Where we have made a business decision to engage with a trusted service provider to assist us with certain functions, including data storage, combining and analysing data and processing data; 
• For disclosures between our related companies. Our main business locations are in Indonesia;
• Where you are involved with public liability issues, we may share your personal information with our overseas insurer or other supplier of relevant services in the course of managing those issues.

12. How can I access my personal information?

You have a right to request access to the personal information we hold about you. You can access or correct your personal information on your online profile via your online account at any time. However, before we provide you with access to your personal information we may require verification of proof of identity. There is no charge to submit a request to correct or access your personal information, however, we may charge a reasonable fee for giving access to your personal information if your request requires substantial effort on our part. 

If you would like a copy of the personal information held by us about you, please contact Almaluna’s staff or management.

13. How can I correct my personal information?

If you believe that any of your personal information is inaccurate, out of date, incomplete, irrelevant or misleading, please contact our staff or management. It is your right to have your personal information corrected.

How can I make a complaint about the management of my personal information?

If you would like to complain about a breach of the Indonesia Privacy Principles, you may contact our staff or management. We may ask you to put your complaint in writing and to provide relevant details. We may discuss your complaint with our personnel and our service providers and others as appropriate. We will respond to your complaint in a reasonable period of time (usually within maximum 30 days).

14. What other privacy terms may apply?

There may be additional privacy notices and terms relevant to you depending on the nature of your dealings with us and on our particular businesses. There are additional privacy terms in our loyalty program and club membership terms and for use of our online sites, for example. 

This policy does not apply to the personal information of our team members (employees and contractors) in their capacity as such.

How to contact ?

If you have any questions about our Privacy Policy or the way in which we collect, hold, secure, use or share your personal information, please contact us