Privacy Policy — JSM One

Application:

JSM One (com.ptjsm.one)

Developer and data controller:

PT. Jeyoti Samertha Mandala

Registered address:

Komplek Pergudangan Paluh Cahaya Mas No. 88, Deli Serdang, Sumatera Utara, Indonesia

Privacy contact:

[email protected]

Effective date:

10 August 2026

Last updated:

10 August 2026

1. Introduction

JSM One is a private, employee-only enterprise resource planning application. PT. Jeyoti Samertha Mandala distributes it to its own employees and authorised personnel. Accounts are issued by HR and IT administrators — there is no public sign-up, and the app cannot be used by members of the general public.

This policy explains what personal data the app collects, why, how it is used, shared, secured, and retained, and how you can exercise your rights over it. It covers the Android and iOS applications and the backend they connect to at api.pt-jsm.com.

By using the app you acknowledge these practices. Where processing relies on your consent — camera, location, and face biometrics — you can withdraw it at any time, as described in section 9. Some workplace features stop working without it.

2. Summary — what we collect

Every item below is collected by PT. Jeyoti Samertha Mandala, encrypted in transit, shared with no third party, and deletable on request.

Not collected: advertising ID, contacts, SMS, call logs, browsing history, health data, audio.

We do not sell your personal data. We do not use it for advertising. We do not share it with data brokers.

3. Personal data we collect and why

3.1 Account and identity data

Provided by your employer when your account is provisioned, and returned to the app when you sign in:

• Employee identifier and internal user ID
• Full name and display name
• Work e-mail address and phone number
• Profile photo
• Company, branch, department, job position, roles and permissions
• Account status and date of joining

Purpose: to authenticate you, show data appropriate to your role, and operate HR workflows. Legal basis: performance of the employment contract, and our legitimate interest in administering the workplace.

3.2 Attendance and location data

When you clock in, clock out, or start or end a break, the app transmits:

• Precise GPS coordinates (latitude and longitude) captured at that moment
• The BSSID — hardware identifier — of the Wi-Fi network your device is connected to
• A timestamp and your employee identifier
• Where face biometrics are enabled for you, a short set of camera frames (see 3.3)

Purpose: to verify that attendance genuinely occurs at an approved company working location, and to prevent attendance fraud. Legal basis: performance of the employment contract, and legitimate interest in accurate payroll and attendance records.

Location is collected only at the moment you actively perform an attendance action. The app does not track your location continuously, does not collect location in the background, and does not build a movement history of your device. It is used for nothing other than attendance verification.

The app also displays a map of approved working locations. Map tiles are served by OpenStreetMap — see section 5.

3.3 Face images and biometric data — sensitive data

If your employer enables face-biometric attendance for your account, the app will:

1. Face enrolment — ask you to record a short set of camera frames while performing on-screen liveness actions, such as turning your head or blinking. These frames are uploaded to PT. Jeyoti Samertha Mandala's backend and used to create and store your face reference.
2. Attendance verification — at each clock-in and clock-out, capture a further short set of camera frames and upload them so the backend can confirm that a live, matching person is present.

What this means:

• Face frames are biometric data and are treated as sensitive personal data.
• They are used solely for identity verification in attendance — never for surveillance, emotion analysis, profiling, advertising, or any secondary purpose.
• They are transmitted over HTTPS to PT. Jeyoti Samertha Mandala's own servers and are not sent to any third-party biometric or AI service.
• The camera is used only on the enrolment and verification screens, only while that screen is open, and never in the background.
• Capture requires your explicit camera permission and your active participation.
• You may request re-enrolment or deletion of your face data at any time (see section 9). Where face verification is mandatory for your role, deletion means attendance moves to an alternative process agreed with HR.

3.4 HR profile data (Employee Data Renewal) — sensitive data

When you submit or update an Employee Data Renewal request, you may provide — depending on the fields your employer requires — home and domicile address, date and place of birth, gender, marital status, religion, ethnic group, nationality, national identity (NRIC/KTP) number, passport number, driving licence numbers, BPJS Kesehatan and BPJS Ketenagakerjaan numbers, education history, courses, employment history, language proficiency, family members and relatives, emergency and reference contacts, social activities, height and weight, hobbies, vehicle ownership, and social media profile links.

Some of this is sensitive data under applicable law — notably religion, ethnic group, and national identity numbers. It is collected because Indonesian employment, tax and social-security administration requires it, processed strictly for HR record-keeping and statutory compliance, and reviewed only by authorised HR personnel.

3.5 Files and attachments

Photos selected from your gallery, photos taken with the camera, and documents up to 10 MB (PDF, DOC, DOCX) that you attach to leave requests, data renewal requests, or your profile picture. The app accesses your photo library or camera only when you actively choose to attach a file. We do not scan or index your gallery.

3.6 Requests, approvals and communications

Leave requests, leave cancellation requests, overtime and actual overtime requests, duty schedules, approval chains, log notes, and the in-app notifications and announcements you receive.

3.7 Technical data

• App version and build number, operating system version
• Network connectivity status
• Authentication and refresh tokens, and their expiry
• Locally cached preferences: theme, language, "remember me", last active branch and view, seen announcement IDs, notification checkpoint

The app contains no third-party analytics, advertising, crash-reporting or tracking SDK. We do not collect the Advertising ID and we do not track you across apps or websites.

4. Permissions we request, and why

Permissions are requested at the point of use, with an in-context explanation, and never at first launch without explanation. Denying a permission never causes the app to collect that data another way.

5. Third parties and data sharing

We do not sell, rent, or trade your personal data, and we do not share it for advertising or marketing purposes. Your data is shared only in these limited circumstances:

1. Within your organisation — authorised HR staff, your managers, and designated approvers see the data relevant to their role. For example, an approver sees the leave request they must approve. Role-based permissions enforce this on the backend.
2. Hosting infrastructure — the ERP backend is operated for and on behalf of PT. Jeyoti Samertha Mandala by our infrastructure provider, acting as a data processor under contract and permitted to process the data only on our instructions.
3. Legal obligation — where disclosure is required by Indonesian law, a valid court order, or a lawful request from a competent authority, or is necessary to establish, exercise or defend legal claims.
4. Corporate transaction — in a merger, acquisition or restructuring, subject to the acquirer honouring this policy. You will be notified before your data becomes subject to a different privacy policy.

Third-party services contacted by the app:

Neither service receives your identity, your attendance records, or your face data.

6. Data security

• All communication between the app and the backend uses HTTPS/TLS encryption.
• Authentication and refresh tokens are stored in hardened platform storage — Android Keystore and EncryptedSharedPreferences, and the iOS Keychain — not in plain files.
• Sessions expire, and expired or invalid credentials trigger automatic sign-out. An unauthorised response clears local credentials immediately.
• Backend access is protected by role-based access control; employees can reach only their own records.
• Face frames and attachments are transmitted directly to PT. Jeyoti Samertha Mandala's backend and are not cached on the device beyond the moment of upload.
• Passwords must be at least 12 characters.

No method of transmission or storage is completely secure. While we apply appropriate technical and organisational measures, we cannot guarantee absolute security. If a data breach affecting your personal data occurs, we will notify affected users and the relevant authority as required by applicable law.

7. Data retention

Signing out or uninstalling the app clears locally stored tokens, cached profile data and preferences from your device. It does not delete records held on PT. Jeyoti Samertha Mandala's ERP servers, which remain subject to the retention periods above.

8. Children's privacy

JSM One is an internal workplace tool intended solely for employees of PT. Jeyoti Samertha Mandala who are of legal working age. It is not directed at children, contains no child-appealing content, and we do not knowingly collect personal data from anyone under 18. If we learn that we have collected data from a child, we will delete it promptly.

9. Your rights and choices

Subject to Indonesian Law No. 27 of 2022 on Personal Data Protection, and any other data protection law that applies to you, you have the right to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete data — much of this can be done in-app via Employee Data Renewal
• Delete your personal data, subject to legal and employment record-keeping obligations
• Restrict or object to certain processing
• Withdraw consent for camera, location or face-biometric processing
• Data portability — receive a copy of the data you provided in a structured, commonly used format
• Lodge a complaint with the competent supervisory authority

How to make a request

Send your request to [email protected] from your registered work e-mail, or contact your HR department directly. State clearly what you are asking for. We will verify your identity and respond within 30 days.

Account and data deletion

Because JSM One accounts are issued and controlled by your employer, accounts cannot be created or deleted from inside the app. To request deletion of your account and associated personal data:

1. E-mail [email protected] with the subject line "Data Deletion Request", or submit a request to your HR department.
2. Include your full name and employee identifier.
3. Specify whether you want all personal data deleted, or only specific categories — for example, "delete my face enrolment data only".

We will delete the requested data within 30 days, except where retention is required by law — for example, payroll, tax and attendance records that must be kept for statutory periods. Data we must retain is restricted to that legal purpose and remains protected under this policy. We will tell you which data was deleted, which was retained, and why.

Withdrawing permissions

You can revoke camera, location or photo-library access at any time in your device settings. On Android: Settings → Apps → JSM One → Permissions. On iOS: Settings → JSM One. Attendance and face-verification features will stop working until access is restored.

10. International data transfers

The ERP backend is operated for PT. Jeyoti Samertha Mandala and personal data is processed primarily in Indonesia. Where any processing or storage occurs outside Indonesia, we ensure an adequate level of protection through contractual safeguards with our processors, consistent with Indonesian Law No. 27 of 2022.

11. Changes to this policy

We may update this policy to reflect changes in the app, our practices, or the law. The "last updated" date at the top will change. For material changes — for example, a new category of data collection or a new sharing arrangement — we will notify you in advance through an in-app announcement or by e-mail, and where the law requires it, obtain your consent before the change takes effect. Continued use of the app after a change takes effect indicates acceptance of the revised policy.

12. Contact us

PT. Jeyoti Samertha Mandala — Data Privacy

• E-mail: [email protected]
• Address: Komplek Pergudangan Paluh Cahaya Mas No. 88, Deli Serdang, Sumatera Utara, Indonesia

For questions about this policy, to exercise your rights, or to report a privacy concern, contact us at the address above. We aim to acknowledge every enquiry within 7 days and resolve it within 30 days.

Appendix A — Google Play data safety mapping

For completing the Data safety form in Google Play Console. Every entry is collected, encrypted in transit, not shared with third parties, and deletable on request.

Also declare in Play Console:

• Data is encrypted in transit — yes
• Users can request that data be deleted — yes, via [email protected]
• Data deletion URL for the store listing — the "Account and data deletion" section of this page
• Independently validated against a global security standard — no
• Committed to the Play Families policy — no, the app is not directed at children
• Advertising ID — not collected
• Sensitive permissions — precise location and camera, justified by attendance verification and face-based identity verification, each preceded by a prominent in-app disclosure

Appendix B — Prominent in-app disclosure

Google Play requires a prominent in-app disclosure before location and camera data is collected. The app presents the following before first use of each.

Location access

JSM One collects your precise location when you clock in, clock out, or start and end a break, to confirm that the action was performed at an approved company work location. Location is collected only at that moment and is never collected in the background. Attendance cannot be recorded without it.

Camera and face verification

JSM One uses your camera to record a short set of face frames during enrolment and each attendance action. These frames are sent to your employer's servers to confirm your identity and prevent attendance fraud. They are not used for any other purpose and are not shared with third parties. You can request deletion of your face data at any time.

This document is provided for the JSM One mobile application and is not legal advice. PT. Jeyoti Samertha Mandala should have it reviewed by counsel before publication, to confirm compliance with Indonesian Law No. 27 of 2022 and any other law applicable to its workforce.