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Privacy Policy

PT Free The Sea (hereinafter referred to as "FTS" "we" or "us") is committed to protect your personal data that you share with us, in complying with the requirements of the Personal Data Protection Law of Indonesia (the “PDPL”), like General Data Protection Regulation (“GDPR”) and other applicable laws and reulations. In doing so, we will ensure compliance by our staff with the strictest standards of security and confidentiality.


We recognize the importance of the Personal Data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your Personal Data.

This Privacy Policy will apply to all Personal Data that is collected, used, disclosed, processed, and retained by us, including Personal Data that we collect online through or in connection with this website [] (this “Website” or “Site”).  

In this policy, “Personal Data” means any data about an individual who can be identified from that data, or from that data in combination with other information to which the organization may have access and includes the meaning otherwise as defined in the Act as amended from time to time.

If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your Personal Data, please do not hesitate to contact us.

Data controller

The data controller for the collection, processing and use of your personal data is:

PT Free The Sea  
Panbil Industrial Estate
Factory A Lot 5-9
Kel. Muka Kuning, Kec. Sei Beduk
Batam 29433 Indonesia


If you have any concerns about data protection, you can also contact our company data protection officer:

PT Free The Sea
Panbil Industrial Estate
Factory A Lot 5-9
Kel. Muka Kuning, Kec. Sei Beduk
Batam 29433 Indonesia

If you wish to object to the collection, processing or use of your data by us in accordance with this privacy policy as a whole or for individual measures, you can address your objection to the data controller.

You can save and print out this privacy policy at any time.

Purpose of data collection

We may collect your personal data that you may volunteer on our website, by telephone or facsimile, mail or other means. Personal data collected from you may be used for any of the following purposes and/or for other purposes as may be agreed between you and us and/or as required by law. We do not collect or use personal data for any purpose other than below and state the propose for which personal data we will use before you provide personal data to us. 

  • Transaction support

Assisting you in completing for transactions and orders, managing and administering accounts, order fulfillment, delivering or providing or to be delivered or provided any services.

  • Customer service

Establish and maintain our relationship with you and provide on-going service(s) and comprehensive customer support by maintaining accurate contact and registration data, including administering product warranties, responding to complaints or enquiries, offering products, services, and features, promotions that may interest you and enabling you to participate in events and questionnaires. 

  • Business operations

Conducting ordinary business operations, verifying your identity, research and analytics, corporate reporting and management, staff training and quality assurance purposes (which may include monitoring or recording calls to our customer support) and outreach. To store, host and/or back up (whether for disaster recovery or otherwise) your Personal Data, whether within or outside Hong Kong.

  • Compliance with Law

Compliance with applicable laws, regulations, court orders, government and law enforcement requests, to operate our services and products properly and to protect ourselves, our users and our customers and to solve any customer disputes. However, during judicial proceedings, in order to cooperate with the government to investigate or protect the rights of FTS, we may need to disclose your personal information in accordance with the law in response to the court judgment or legal process of FTS.

Information we collect

We may collect and process Personal Data about you such as:

  • Personal and business contact information, such as name, mailing address, phone number, and e-mail address that you provide through filling out forms or submit on this Website, our service centres, and any customer surveys.

  • Unique information such as user IDs and password.

  • Internet Protocol address of the computer you are using.

  • Details of products and services which you purchase from us or which you have inquired about, such as model, serial number, and dealer name.

  • Details of your visits to our Website, the activities you engage in when using the services made available via the Website and the resources that you access on or via the Website.

  • Personal background information reasonably required for recruitment and administration of employees

  • Name and URL of the retrieved file, Date and time of retrieval

  • transferred data volume

  • Message about successful retrieval (HTTP response code)

  • Browser type and browser version

  • Operating system

  • Referrer URL (i.e. the previously visited page)

  • Websites accessed by the user's system through our website

  • Internet service provider of the user

  • IP address and the requesting provider

Log Data

Like many site operators, we collect information that your browser sends whenever you visit our Site ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we may use third party services such as Google Analytics to analyze our visitors profile and behavior.



Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive. Like many sites, we use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

Third Party Sites

You may be able to access third party web sites through links available on our Site. You understand and agree that your use of third party sites will be governed by the privacy policies of those web sites and not by this Privacy Policy. The privacy policies of other web sites may differ from this Privacy Policy to reflect differences in site features, company services or applicable law.


We are dedicated to protect the quality and integrity of your Personal Data. For this we have adopted industry-standard security technologies, procedures and organizational measures, to protect your data from unauthorized access, use or disclosure. We also encourage you to take precautions to protect your Personal Data from security breach. For example, where we have given you, or where you have chosen, a password to access certain parts of the Website or your registered user account, you should not share this password with others.

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Disclosure of the information

Your Personal Data may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Hong Kong or outside of Hong Kong, for the purposes set out above:

  • Our headquarters, subsidiaries and group companies.

  • Third party service providers which require the processing of your data, for example, third party service providers which have been engaged by us to : (i) to provide and maintain any IT equipment used to store and access your Personal Data; (ii) to host and maintain this Website; or (iii) otherwise in connection with the provision of certain services provided to you on or via this Website.

  • Our auditors and legal advisors.

  • Respond to duly authorized information requests of law enforcement agencies, regulators, courts and other public authorities, including to meet national security or other law enforcement requirements

  • Comply with any law, regulation, subpoena, or court order

Google Analytics

We use Google Analytics, a web analytics service of Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files, which are stored on your computer and enable the analysis of your website use. The information generated by the cookie about the use of this website by the site visitors is usually transferred to a Google server in the USA and stored there.

This is also our legitimate interest pursuant to Art. 6 para. 1 sentence 1 f) GDPR.

Google has signed and certified itself under the Privacy Shield Agreement between the European Union and the USA. By doing so, Google undertakes to comply with the standards and regulations of European data protection law. Further information can be found in the entry linked below:

We have enabled IP anonymization on this site (anonymizeIp). In this manner, your IP address is however first shortened by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there. On our behalf, Google will use this information to analyse your use of the website to compile reports about website activities and to provide us with other services connected to website use and internet use.

The IP address transmitted from your browser as part of Google Analytics will not be consolidated with other data by Google. You can prevent the storage of cookies by configuring your browser software accordingly; we would however like to point out that, in this case, you may probably not be able to fully use all functions of this website.

Furthermore, you can prevent Google from transferring the data generated by the cookie and related to your use of the website (incl. your IP address) as well as from processing this data by downloading and installing the browser plugin available under the following link:

As an alternative to the browser plug-in or within browsers on mobile devices, you can click the following link to set an opt-out cookie to prevent future collection by Google Analytics within this website (this opt-out cookie only works in this browser and only for this domain. If you delete the cookies in your browser, you must click this link again): [Disable Google Analytics]


Storage Duration

Unless specifically stated, we only store personal data for as long as is necessary to fulfil the purposes pursued.

In some cases, there are statutory requirements for the storage of personal data, for example in tax or commercial law. In these cases, the data will only be stored by us for these legal purposes, but will not be processed in any other way and deleted after expiry of the legal retention period.  

Your rights as a data subject 

According to the applicable laws, you have various rights regarding your personal data. If you wish to assert these rights, please send your request, clearly identifying yourself, by e-mail or by post to the address specified in section 1. Should you make use of your rights listed below, we will check whether the legal requirements for this have been met.

Below you will find an overview of your rights.

a) Right to confirmation and information
You have the right to clear information about the processing of your personal data.

In detail:
You have the right to receive confirmation from us at any time as to whether personal data relating to you is being processed. If this is the case, you have the right to request free information from us about the personal data stored about you together with a copy of this data. Furthermore, there is a right to the following information:

  • the purposes of processing;

  •  the categories of personal data being processed;

  •  the recipients or categories of recipients to whom the personal data have been or are still being disclosed, in particular, recipients in third countries or international organisations;

  • if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration;

  • the existence of a right to have the personal data concerning you rectified or deleted or to have the data controller restrict processing or a right to object to such processing;

  • the existence of a right of appeal to a supervisory authority;

  • if the personal data is not collected from you, all available information about the origin of the data;

  • the existence of automated decision making including profiling pursuant to Art. 22 para. 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved as well as the implications and the envisaged effects of such processing for you.


If personal data is being transferred to a third country or an international organisation, you have the right to be informed of the appropriate guarantees in accordance with Art. 46 GDPR in connection with the transfer.


b) Right to rectification
You have the right to ask us to correct and, if necessary, complete any personal data concerning you.

In detail:
You have the right to request us to promptly correct any inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data - also by means of a supplementary declaration.

c) Right to erasure ("right to be forgotten")

In a number of cases we are obliged to delete personal data concerning you.

In detail:
Pursuant to Art. 17 para. 1 GDPR, you have the right to demand that we promptly delete personal data concerning you, and we are obliged to promptly delete personal data if one of the following reasons applies:

  • The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.

  • You revoke your consent, upon which the processing was based pursuant to Art. 6 para. 1 sentence 1 a) GDPR or Art. 9 para. 2 a) GDPR and there is no other legal basis for the processing.

  • You file an objection to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for processing, or you file an objection to the processing pursuant to Art. 21 para. 2 GDPR.

  • The personal data have been processed unlawfully.

  • The deletion of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States, to which we are subject.

  • The personal data was collected in relation to offered information society services in accordance with Art. 8 para. 1 GDPR.

    If we have made the personal data public and we are obliged to delete them pursuant to Art. 17 para. 1 GDPR, we will take appropriate measures, including technical measures, taking into account the available technology and implementation costs, to inform those responsible for data processing, who process the personal data, that you have requested them to delete all links to this personal data or copies or replications of this personal data.


d) Right to restriction of processing
In a number of cases you are entitled to request us to restrict the processing of your personal data.

In detail:
You have the right to request us to restrict processing if one of the following conditions is met:

  • the accuracy of the personal data is disputed by you for a period that enables us to verify the accuracy of the personal data,

  • the processing is unlawful and you have rejected the erasure of the personal data and have instead requested the restriction of the use of the personal data;

  • we no longer need the personal data for the purposes of processing, but you need the data to assert, exercise or defend legal claims, or

  • You have filed an objection to the processing pursuant to Art. 21 para. 1 GDPR, as long as it is not yet clear whether the justified reasons of our company outweigh yours.


e) Right to data transferability
You have the right to receive, transmit or have us transmit personal data concerning you in machine-readable form.

In detail:
You have the right to receive the personal data concerning you that you have provided to us in a structured, current and machine-readable format, and you have the right to transmit this data to another data controller without our interference, provided that

  • processing is based on consent pursuant to Art. 6 para. 1 sentence 1 a) GDPR or Art. 9 para. 2 a) GDPR or on a contract pursuant to Art. 6 para. 1 sentence 1 b) GDPR and

  • processing is carried out using automated methods.


When exercising your right to data transferability in accordance with paragraph 1, you have the right to request that the personal data be transferred directly by us to another data controller, insofar as this is technically feasible.

f. Right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you on the basis of Art. 6 para. 1 sentence 1 e) or f) GDPR; this also applies to profiling based on these provisions. We no longer process personal data unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If we process personal data for direct advertising purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct advertising.

You have the right, for reasons arising from your particular situation, to object to the processing of personal data concerning you, for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 GDPR unless the processing is necessary to fulfil a duty in the public interest.

g) Automated decisions including profiling
You have the right not to be subject to a decision based exclusively on automated processing - including profiling - that has legal effect on you or significantly impairs you in a similar manner.
Automated decision making based on the collected personal data does not take place.

h) Right to revoke consent under data protection law
You have the right to revoke your consent to the processing of personal data at any time.

i) Right of appeal to a supervisory authority
You have the right of appeal to a supervisory authority, in particular in the Member State of your place of residence, your workplace or the place of the suspected infringement, if you believe that the processing of personal data concerning you is unlawful.


Changes to this Privacy Policy

This Privacy Policy is effective as of 01.01.2023 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Contact Us

If you have any questions about this Privacy Policy, please contact us.

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