Privacy Policy

Temple art development Company Limited (the "Company") is the owner and the developer of Pavara group  (the “Platform”). By signing up and registering to be the user to use the service of the Platform (“User”), the User acknowledges and understands that the Company would need to process the personally identifiable information (the "PII") of such particular User. Thus, the Company announces this Privacy Policy to notify the User of the rights and obligations as well as the conditions for the collection, use, process and disclosure of the User's PII.

This Privacy Policy is only applicable to the use of the Platform and shall not apply to the PII process undertaken by other application or website developed and operated by any other third-party that the Company does not have any control over (the "Third Party") that being displayed or connected to the Platform. The User understand and agree that the User shall study and agree on the privacy policy announced by those Third Party that are separated from this Privacy Policy.

If the User does not accept this Privacy Policy and any amendment thereof, the Company reserves the rights to refrain from providing any services to those Users since the processing of the PII defined hereunder are critical for the provisions of the Platform services by the Company to the User. By continuing to use the Platform, the relevant User shall be deemed to always accept and agree to the Privacy Policy.

The Company may amend or revise this Privacy Policy at any time to assure the compliance with the relevant laws and regulations and to assure the updates in the Platform at any time; provided that the Company will communicate the amendments or revisions made on the Platform and the amendment or revisions shall become effective once communicating on the Platform.

What kind of PII is being Processed?

In order to perform the required services and features defined on the Platform, the Company would need to collect and process the following PII from the User:

1. Directly Identifiable PII such as name, age, nationality and date of birth
2. Contact information such as address, phone number, and e-mail address
3. Payment information such as the payment transaction information, bank account information and credit card information
4. Transactional data, such as username - password and logs, transaction number and history that the User transact and use the Service, including the gathered preference and interest from the transactional behavior
5. Data that specifies your location while using the website. If you enable the GPS system, you consent the Company to collect and process your location information. However, if you would like to conceal this information, you can install programs or turn off GPS on your mobile phone.
6. Necessary information to be provided to the Company and the Company is entitled to process such personal data as stipulated by law without consent as follows:
7. Data to be provided for complying law or performance or execution of a contract or other data as stipulated by law. If you do not give your personal data, the Company may not be able to proceed with such action requested by you or as the Company informs you or other consequences pursuant to the applicable law.
8. Data that is necessary for any lawful interest such as the collection of photo from the Company’s activities and etc.
9. Technical PII such as IP address number, the Service usage information, and web browser status and setting that have been used to connect to the Service.

How the Platform is processing the User’s PII?

• The Company would need to collect, restore and use the PII of the User in order to perform any services or features of the Platform as defined under the Terms of Use, including without limitation (i) to verify the identity and eligibility of the User; (ii) to monitor the transaction undertaken on the Platform executed by the User; (iii) to contact the relevant User; and (iv) to display the relevant PII on the Platform interface in accordance with the scope of services provided under the Terms of User / Terms of Services;
• The Company would need to collect and analyze the PII of the User in order to assess the User’s interest with an aim to provide customized and personalized privileges or service that would meet your interest and preference and to improve our customer’s experience with each relevant User;
• The Company would need to collect and restore the User’s PII in order to assure the appropriate after-sale service provided by the Company in various forms, including the satisfaction survey or the support and complaint redress function;
• The User would need to collect and restore the User’s PII as obliged under the applicable laws and regulations, for instance, for the withholding tax payment purpose.

The Company would need to collect and store the PII of each relevant User for the defined purposes for as long as the User is still the registered User on the Platform and for 3 (three) years after the User termination, except the relevant laws and regulations defined otherwise. The storage of the PII after the User termination would be necessary for the legitimate interest of the Company in the legal proceedings that the Company may have against the relevant User.

Potential Receivers of Your Personal Data

• The Company, partners of the Company or any employee of relevant companies.
• Agents of the Company who has been authorized to offer and sell the Company’s products and services, including agent or person hired by such person.
• Other persons, including agent or person hired by such person who is arranging in connection with the Company’s products and services, the conduct of the marketing activities, the offer of the Company’s information, the development of the Company’s products and services, e.g. payment method, documentation system, technology, delivery of documents, research, etc.
• Condominium Juristic Person or Developed-Estate Juristic and /or Condominium manager or Developed-estate manager.
• Any governmental authority or supervision organization or any person to which the Company is required to disclose such data whether by laws, regulations or order in relation to the Company or pursuant to the Company’s agreement with any governmental authority or any other person.

What are Cookies that the Company is using on the Platform?

Cookies are text files stored on the User’s computer browser directory or program data subfolder in order to keep data log of the User’s internet usage and the User’s behavior or interaction on the Platform. For the performance of the Platform, the Company need to use various types of Cookies for various purposes as defined below:

• Functionality Cookies being used to record information about choices the User have made in the Platform such as personal settings, languages, and fonts so this would allows the Company to tailor our Platform features that would match the User’s preference setting;
• Advertising Cookies being used to record the User’s on-site behavior and history of the Platform visited and this would allow the Company to provide the User the services and products that suit the User’s preferences and to assess the success of each function of the Platform.
• Strictly Necessary Cookies are essential for the User to browse the Platform and use its features, such as accessing secure areas of the Platform.

Even though the use of Cookies would enhance the performance in providing services in any features of the Platform to the User, the User shall be entitled to disable the Cookies setting on the User’s browser at their own will; provided that the User shall acknowledge that the Cookies-disabled setting may impact the efficiency and the performance of the Platform as defined in details for each type of Cookies above.

Representation on the Privacy Security

The Company represents and guarantees that the Company shall adopt the ‘Privacy-by-Design’ concept and shall use the most appropriate security measures to prevent the unauthorized access, amendment or disclosure of the PII in any form or in any circumstance by either internal or external persons and the Company commits to review those measures on the regular basis with the strong commitment to use the best industrial practice and to be in strict compliance with the applicable laws.

Data Subject Rights

The Company acknowledges and accepts the User’s rights as the data subject over their PII as defined under the applicable laws that include the following rights:

• Right to withdraw consent: Users can withdraw their consent and request the processors to stop collecting their personal data.
• Right of Access: Users can submit data access requests, which oblige processors to provide a copy of any personal data they hold regarding data subjects. This includes a request for a disclosure of platforms and methods in which the processors collected the data from.
• Right of Rectification: Users can request an update on an inaccurate or incomplete personal data.
• Right to Restriction of Processing: Users can request the service provider to limit the way their personal data is used.
• Right to be informed: Users have the right to be notified about the collection of their personal data such as storage periods and purposes.
• Right to Object: Users can object to the processing of personal data that is collected on the grounds of legitimate interests or the performance of a task in the interest/exercise of official authority.
• Right to Data Portability: Users are permitted to obtain and reuse their personal data for their own purposes across different services.
• Right to Erasure: Users can request that the service provider erase their data in certain circumstances, such as when the data is no longer necessary, the data was unlawfully processed or is no longer meeting the lawful ground for which it was collected. This includes the instance where the individual withdraws consent.
• Right not to be subject to automated individual decision-making: significant decision will not be solely based on automated means.

The User can contact the Company in order to make the request to exercise any defined rights through the defined channel without any charge and the Company will consider and notify the User of the Company’s determination within 30 days after the receipt of the User’s valid request.

Changes to our Privacy Policy for personal data protection / Contact of the Company

• Company may change or update details of Privacy Policy for personal data protection in part or in its entirety. If there is a change, the Company will update its Privacy Policy for personal data protection on the website.
• Users may express his or her opinion on the Privacy Policy for personal data protection at "Contact Us". However, users agree that the Company's discretion is absolute.