Privacy Policy

The following Privacy Policy describes how Yayasan WWF Indonesia, a non-profit organization duly established and legally operating under the laws of the Republic of Indonesia and domiciled in Jakarta, Indonesia. Hereinafter referred to as "us", "we", or "our", collect, store, use, process, retain, transfer, disclose and protect your Personal Information (defined below). 

This Privacy Policy applies to all users of the Hamurni platform, which includes, but not limited to, the mobile application, feature phone service and online dashboard (dashboard.hamurni.com) (collectively referred to as "Hamurni Platform"). The Hamurni Platform is a traceability tool for sustainable commodities through mapping and managing your commodities transactions.

This Privacy Policy is an agreement between users (“you, your or yourself”) and us. Please read this Privacy Policy thoroughly to ensure that you understand our data processing practices. 

1. • Information we collect

2. We collect your personal information which identifies or can be used to identify you (“Personal Information”) for the purpose of processing your commodity transaction, managing and carrying out the use of the Hamurni Platform as described in this Privacy Policy.

3. Personal Information includes your name, home address, date of birth, role in the commodity transaction, phone number, e-mail address, gender and educational background. Additionally, to the extent other information, including a personal profile, and/or unique identifier, is associated or combined with Personal Information, then that information is also Personal Information.

4. Personal Information also includes your commodity transaction information:

5. Suppliers (farmers, plantation owner, plantation manager, agent, cooperative, delivery order holder and vehicle driver) using the Hamurni Platform will provide us with the relevant information as it may reasonably be required for the effective operation of the Hamurni Platform, including:

6. specifically for suppliers that own a plantation, physical address and geolocation of the plantation (polygon), plantation size, plantation details (number of planted trees, seed type, age of trees etc.) and legal documents such as Rights over Land Certificate (SHM/HGU/HGB), and Location Permit/Plantation Business License (IUP-B, STD-B);

7. details of your commodity transactions including:

• associated farmer group (if relevant);

• type of commodity;

• name and phone number of people you trade/work with (e.g. driver, agent);

• amount of commodity sold or bought;

• collection point of the commodity;

• transportation used for the collection (license plate, photo of the vehicle, capacity of the vehicle, and approvals or other authorizations for you to use the vehicle);

• Delivery Order;

• Date and time arriving at and departing from mill; and

• the mill your commodities are supplied to.

2. Mills using the Hamurni Platform have to provide us with relevant Personal Information as may reasonably be required by us in order for the operation of the Hamurni Platform:

1. Mill name, mill address and role in the mill;

2. details of your commodity transactions including:

• Delivery Order;

• Transportation arriving and departing from mill (license plate, photo of the vehicle, capacity of the vehicle, and approvals or other authorizations for you to use the vehicle);

• Date and time mill arriving at and departing from mill;

• Amount of commodity sold or bought (nett);

• Name and phone number of the people you interact with.

3. Users of the Hamurni Platform may need to provide us with other information that we request in the future for us to operate and monitor the Hamurni Platform.

4. The Personal Information which we collect may be provided by you directly or by third parties (for example: when you register or use the Hamurni Platform, when you contact Hamurni service desk, or you otherwise provide Personal Information to us). We may collect your Personal information in various forms and purposes (including purposes permitted under applicable law).

Information collected whenever you use the Hamurni Platform

1. we may collect certain technical data concerning your usage such as, internet protocol (IP) address, duration of every visit/session, the internet device identity (ID) or media access control address, mobile advertising ID and other device information including information regarding the manufacturer, model and operating system of the device that you use to access the Hamurni Platform.

2. certain information may also be collected on an automated basis using cookies. Cookies are small application files stored on your computer or mobile device. We use cookies to track user activity to enhance user interface and experience. You may adjust the settings on your mobile device or internet browser to reject several types of certain cookies or certain specific cookies and delete at any time whatever cookies have previously been stored. However, doing so may affect the functionalities available on the Hamurni Platform.

3. In some cases, you will be prompted or required to activate the Global Positioning System (GPS) on your mobile device to enable us to give you a better experience in using the Hamurni Platform (for example, to locate your plantation location). 

Information collected from third parties

We may also collect your Personal Information from third parties (including your transaction counterparts who use Hamurni Platform and perform transactions with you and any others who provide services to us, who collect your Personal Information and/or perform functions on our behalf, or whom we collaborate with). In such cases, we will only collect your Personal Information for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be).

Information about third parties you provide to us

You may provide us with Personal Information relating to other third-party individuals (connected to your transactions). You will need their consent to do so – see Clause 10 on Acknowledgement and Consent below for further information.

2. • The Use of Information Which We Collect

We may use your Personal Information collected for the purposes authorized by you and any of the following purposes (“Purposes”):

1. to identify and register you as a supplier, mill or buyer user and to administer, manage or verify your account as such;

2. to achieve traceability of commodities by registering suppliers, commodity sources and transactions in upstream supply chains from plantations to mill;

3. to provide you bespoke analysis and information of your transactions to monitor trends and ease work-flows;

4. to communicate with you and to send you information, updates and changes in connection with the use of the Hamurni Platform;

5. monitor and analyse your activities, behaviour, and demographic data including trends and usage of the various services available on the Hamurni Platform;

6. where you are a supplier, we may use your Personal Information to:

7. map and track your transactions including all current and past purchases or sales of commodities, as aggregated per period (day, week, month) or as a list of individual transactions;

8. map your commodity sourcing places including plantations and collection points location;

9. analyse your Personal Information to identify legal and environmental risks based on Hamurni Plaform’s risk assessment tool and obtain overall supplier rating score;

10. take prompt interventions against commodity sources which are not in compliance with the mills and buyers’ responsible sourcing policy, such as the No Deforestation, No Peat, No Exploitation Policy (NDPE Policy), via real time mapping of the upstream flow of commodities;

11. issue and administer rewards programs including goods vouchers and training programs;

12. design targeted farmer outreach and training programs including content design, delivery mode, and location of physical training;

13. notify on interesting news and tips such as best agricultural practices and access to incentives that are bound to improvements of sustainability indicators.

7. where you are a mill, we may use your Personal Information:

1. to map your upstream supply chains;

2. to track all past commodities purchases, as aggregated per period (day, week, month) or as a list of individual transactions;

3. to analyse Personal Information of your suppliers and your transactions collected in the Hamurni Platform and identify legal and environmental risks based on Hamurni’s risk assessment map and your suppliers’ overall rating score;

4. take prompt interventions against commodity sources in your supply chain which are not in compliance with your responsible sourcing of policy, such as the NDPE Policy, via real time mapping of the upstream flow of commodities;

5. provide you with a report in relation to your mill’s upstream supply chains that you and your Suppliers have registered in the Hamurni Platform;

6. upon your consent, share data on commodity supplies with other mills without compromising business integrity.

8. we may also use your Personal Information more generally for the following purposes (although we will in each such case always act reasonably and use no more information than what is required for the purpose of the Hamurni Platform):

1. to monitor the usage of the Hamurni Platform and administer, support and improve the performance efficiency, growth, user experience and the functions of the Hamurni Platform; 

2. to provide assistance in relation to and to resolve any technical difficulties or operational problems with the Hamurni Platform;

3. to generate statistical information and analytics data for the purpose of testing, research, analysis, product development and collaboration; 

4. to prevent, detect and investigate any prohibited, illegal, unauthorized or fraudulent activities; and

5. enable us to comply with our obligations under any applicable law (including but not limited to responding to regulatory enquiries, investigations or directives) and conducting audit checks, due diligence and investigations.

9. We retain the right to use the cellular phone number that you have registered to send token codes as a verification media for your account, and for other information on the use of the Hamurni Platform.

3. • Sharing of Information Which We Collect

1. Details of your transaction will be shared to your transaction counterpart that you are involved in directly.

2. You may share details of your plantation, collection point, transport and delivery order to another user of Hamurni Platform for their commodity transaction (“Shared Details”). The recipient of such details (except for mills) will only be disclosed of the following:

• plantation details: plantation name, your name, your responsibility over the plantation, recipient’s responsibility over the plantation and GPS point of the plantation;

• collection point details: collection point name, your responsibility over the collection point, recipient’s responsibility over the collection point and collection point type;

• transport details: license plate number, your responsibility over the transport, recipient’s responsibility over the transport, transport’s loading capacity, color, make and model of the transport;

• delivery order: delivery order ID, your name and mobile phone number, your responsibility over the delivery order, mill that issues the delivery order, and recipient’s responsibility over the delivery order.

3. The recipient of the Shared Details (as described under point b above) may use such received details for its transaction with another Hamurni user that is not connected with you or have not received Shared Details from you. Such other Hamurni users may only see the name of such Shared Details (name of plantation, collection point, transport and delivery order).

4. We may disclose your data and information provided by you or a third party in the Hamurni Platform to mills where your commodity is sourced to, as described below:

• Mills will only be disclosed of their upstream supply chain’s data and information. Suppliers outside of the mills’ supply chain will not be disclosed.

• Mills will be disclosed of your mobile phone number, name, role in the supply chain, village name, endorsement status and category, feature phone mode, farmer survey answer, plantation details (polygon, GPS, address, size and etc.), sustainability certification, collection point ID, vehicle details, Delivery Order ID, farmer group details and transaction details.

• legal and environmental risk based on our analyses of your Personal Information to mills where your commodity is sourced to.

• Information on the Responsibility of Collection Point entry creator and collection point GPS location may be disclosed to the mill if Hamurni Platform indicates that you have legal and/or environmental risk.

5. Buyers using the Hamurni Platform will be disclosed with following data and information of their mill’s suppliers that uses the Hamurni Platform:

• User ID, role in the upstream supply chain, endorsement status, endorsement category, farmer survey answer, plantation ID, risk status of plantation area polygon;

• transaction details in their mill’s supply chains, including summary of Total amount identified to be within the buyer’s supply chain, plantation source, summary of amount per plantation source;

• legal and environmental risks of each of their mill’s suppliers;

• Transaction ID, date&time of transaction form submission, date&time of transport arrival at and departure from mill, total amount (kg) received and segregation type may be disclosed to the buyer if Hamurni Platform indicates that you have legal and/or environmental risk.

6. We may disclose to or share with affiliates and other parties your Personal Information for any of the following purposes as well as for such other purposes as are permitted by applicable law:

1. where required or authorised by applicable law (including but not limited to responding to regulatory enquiries, investigations or directives, or complying with statutory or regulatory filing and reporting requirements), for the purpose so specified in that applicable law;

2. where instructed, requested, required or authorised by the government authorities, for the purpose as specified in the government policy, regulations or applicable law;

3. where there is any form of legal proceeding between you and us, or between you and another party, in connection with, or relating to the Hamurni Platform, for the purposes of that legal proceeding;

4. in relation to any verification as we may consider necessary before we register you as a user;

5. to third parties (including our agents, vendors, suppliers, contractors, partners and any others who provide services to us or you, perform functions on our behalf, or whom we enter into commercial collaboration with) for or in connection with the purposes for which such third parties are engaged, to perform certain disclosure to the relevant third parties which are technically required to process your Personal Information or for the purposes of our collaboration with such third parties (as the case may be), which may include allowing such third parties to introduce or offer products or services to you, authenticate you or connect with your account, or conducting other activities including marketing, research, analysis and product development; and

6. where we share your Personal Information with our affiliates, we will do so for the purpose of them helping us to provide the Hamurni Platform, to conduct our operation, or for the purpose of them conducting data processing on our behalf. For example, a WWF affiliate in another country may process and/or store your Personal Information on behalf of the WWF group in your country. All of our affiliates are committed to processing the Personal Information that they receive from us in line with this Privacy Policy and applicable law.

7. We will not sell, lease or guarantee your Personal Information submitted in the Hamurni Platform.

8. Other than as provided for in this Privacy Policy, we may disclose or share your Personal Information in the Hamurni Platform with your consent.

4. • Retention of Personal Information

1. Your Personal Information in the Hamurni Platform will only be held for as long as your account is open to provide you services of the Hamurni Platform, or for as long as such retention is required or authorised by applicable law. If you delete your account, we will      cease to retain Personal Information, or remove the means by which the Personal Information can be associated with you (see Clause 6 for Termination of your Hamurni Account). 

2. In the event we share your Personal Information to the authorised government institutions and/or other institutions that may be appointed by the government authorities or have a cooperation with us, you agree and acknowledge that the retention of your Personal Information by the relevant institutions will follow their respective policy on data retention.

5. • Access and Correction of Information

1. You may access and/or correct your data and information in the Hamurni Platform through your account page.

2. You may also request us to change or correct data and information in the Hamurni Platform that may not be done by yourself through contacting us in the details below. In this case, we have the right to refuse your requests to change or correct some or all of your information, if it is deemed by us that such information is invalid or contains false information. 

6. • Termination of your Hamurni Account

1. You may terminate your account at any time through the in-app ‘delete account’ feature. Account deletion will take up to 5 working days. Be mindful that if you only delete the Hamurni Platform from your device without using our in-app delete account feature, your information will still be stored with us.

2. After your account has been deleted, your access, public profile, Personal Information and endorsement will be deleted. However, all historical commodity transaction data that involves you will be retained and visible by your transaction counterpart. All transactions associated with you will show that you no longer have an account in the Hamurni Platform. 

7. • Where We Store Your Information

1. The Personal Information that we collect from you will be stored at, transferred to, or processed by third party service providers. We will use all reasonable endeavors to ensure that all such third-party service providers provide a level of protection that is comparable to our commitments under this Privacy Policy.

2. Your Personal Information may also be stored or processed outside of your country by personnel who work for us in other countries, or by our third-party service providers, vendors, suppliers, partners, contractors or affiliates. In such a case, we will, to the best of our effort, ensure that such information remains subject to a level of protection comparable to what is required under the laws of your country (and, in any event, in line with our commitments in this Privacy Policy).

8. • Security of Your Information

1. We will use all reasonable efforts to protect and secure your Personal Information against access, collection, use or disclosure by unauthorised persons and against unlawful processing, accidental loss, destruction and damage or similar risks. Although we will do our best to protect your Personal Information, you acknowledge that we cannot guarantee the integrity and accuracy of any information which you transmit over the Internet, nor guarantee that such information would not be intercepted, accessed, disclosed, altered or destroyed by unauthorised third parties, due to factors beyond our control.

2. You are responsible for keeping your account details confidential and you must not share your account details, including your password and One Time Password (OTP), with anyone and you must always maintain and fully responsible for the security of the device that you use.

3. You must promptly notify us if your username or password is lost, stolen, or used without permission. In such an event, we will remove that username or password from your account and update our records accordingly.

9. • Changes to This Privacy Policy

We may review and amend this Privacy Policy at our sole discretion from time to time, to ensure that it is consistent with our future developments, and/or changes in legal or regulatory requirements. If we decide to amend this Privacy Policy, we will notify you of any such amendments by means of a general notice published on the Hamurni Platform or to your phone number and/or e-mail address set out in your account. The notification of amendment will give you a chance to agree or not to agree to the new terms. If you do not agree to the new terms, you will not be able to use the Hamurni Platform and you may delete your account in the Hamurni Platform.

10. • Acknowledgment and Consent

1. By accepting the Privacy Policy, you acknowledge that you have read and understood this Privacy Policy and you agree and consent to us collecting, using, sharing, disclosing, storing, transferring, or otherwise processing your Personal Information in accordance with this Privacy Policy.

2. In circumstances where you provide us with Personal Information and any other information relating to other individuals (in connection to your transactions), you represent and warrant that you have obtained such individual’s consent for, and hereby consent on behalf of such individual to, the collection, use, disclosure and processing of his/her information by us.

3. You may withdraw your consent to any or all collection, use or disclosure of your Personal Information at any time by giving us reasonable notice in writing using the contact details stated below. Upon receipt of your notice to withdraw consent for any collection, use or disclosure of your Personal Information, we will inform you of the likely consequences of such withdrawal so that you can decide if indeed you wish to withdraw consent.

11. • Anonymous Data

We may create, use, license or disclose your Personal Information in the Hamurni Platform, provided (i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, and (ii) that has been combined with similar data such that the original data forms a part of a larger data set.

12. • Third-Party Platforms

The Hamurni Platform may contain links to websites that are operated by third-parties. We do not control nor accept liability or responsibility for these websites and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. Please consult the terms and conditions and privacy policies of those third-party websites to find out how they collect and use your Personal Information.

13. • Language

The English language version of this Privacy Policy shall be controlling in all respects and shall prevail in case of any inconsistencies with translated versions, if any. 

How to Contact Us

If you have any questions regarding this Privacy Policy or you would like to obtain access and/or make corrections to your Personal Information, please contact [[email protected]].