This Privacy Notice ("Privacy Notice") is effective as of Oktober 1, 2025.

This Notice explains how we, Inessa ("33percentactive", "33P", "we", "our", or "us"), collect, obtain, use, store, process, disclose, and protect your personal data when you access and use our website at [33percentactive.com], as well as the services made available through the Site, including but not limited to account registration, product ordering, payment processing, and customer communication.

Please read this Privacy Notice carefully to understand our policies and practices regarding the protection of your personal data. By using our Site and services, you agree to all terms set forth in this Privacy Notice.

In this updated Privacy Notice, Inessa has improved the layout and structure to make it easier for users to read and understand. We have also aligned key terms and language with current data protection practices. One of the main changes is the shift in terminology from “Privacy Policy” to “Privacy Notice,” and the addition of this summary section as a quick reference guide.

What Data Do We Collect About You?

We collect personal data when you use our website and services, including:

• Identity data: such as your name, date of birth, and gender
• Contact data: such as your email address, phone number, and shipping address
• Transaction and payment data: such as your order history and preferred payment methods
• Technical and device data: such as your IP address, device type, browser, and your activities on our site
• Additional data you voluntarily provide to us

Please note: if you choose not to provide certain data, some features may not be fully available to you.

How Do We Use Your Data?

We use your data to:

• Manage your account and orders
• Provide customer service and important communications
• Enable personalized features and product recommendations
• Tailor promotions and marketing based on your preferences
• Fulfill legal obligations and prevent fraud

Who Do We Share Your Data With?

We may share your data with:

• Logistics partners for product delivery
• Payment service providers
• IT and analytics service providers
• Affiliates and business partners, with your consent (when legally required)
• Legal authorities, if lawfully requested
• We only share data as necessary to operate 33P's services effectively.

Where Do We Process Your Data?

Your data may be processed both within and outside of Indonesia, including by third-party service providers and affiliates, for the purposes of secure service delivery, analytics, and data storage.

How Long Do We Retain Your Data?

We retain your data for as long as:

• You remain an active user; 
• It is necessary to provide you with services; or
• Required by applicable law.

After that, your data will be deleted or anonymized.

How Can You Manage Your Data Rights?

You may:

• Request access to your personal data
• Update or correct your information
• Withdraw your consent or request deletion of your data

Please send your request 

We will respond in accordance with applicable data protection laws.

Contact and Complaints

If you have any questions, concerns, or requests related to this Privacy Notice, please contact us at:

Email:

Website: 33percentactive.com

Future Updates

We may revise this Privacy Notice from time to time. If there are material changes, we will inform you via our website or through your registered email address.

A complete explanation of our data practices can be found in the full version of the Privacy Notice below..

Types of Personal Data We Collect About You

“Personal Data” refers to any information that can be used to identify, contact, or locate an individual or a specific device related to that information. Personal Data includes, but is not limited to, your name, address, date of birth, gender, occupation, phone number, email address, bank account and credit card details, official identity (such as national ID or passport), photograph, nationality, as well as technical and financial information that can directly or indirectly identify you. If any information is associated with or linked to Personal Data, it will also be considered Personal Data.

The type of Personal Data we collect depends on how you interact with our website and services, as well as the nature of the transactions or features you use. Where permitted by applicable law, we may collect, use, store, and transfer both general and sensitive types of Personal Data, which generally include:

Identity Data

Includes your full name, username, password, government-issued ID (such as KTP or tax ID), place and date of birth, gender, occupation, nationality, photo, and biometric data when required for security or verification purposes.

Contact Data

Includes your home address, shipping address, email address, phone number, and contact lists where required—for example, in referral systems or third-party shipping arrangements.

Eligibility Data

In specific contexts such as reseller programs or partnerships, we may collect business permits, legal verification documents, or other supporting materials for verification purposes.

Transaction Data

Includes records of purchases or orders placed on our website, your product preferences, shopping interests, survey responses, and delivery details such as your chosen courier and destination address.

Financial Data

Covers bank account details, credit or debit card information (such as cardholder name, card number, expiry date, CVV code), and payment history through virtual accounts, e-wallets, or bank transfers.

Payment Data

Includes payment transaction details, chosen payment methods, amount paid, recipient information (if different), and invoice or billing records associated with your orders.

Technical Data

Includes information from your device when accessing our site, such as your IP address, device ID, operating system, browser type, session duration, visited pages, and activity logs.

Device Data

Includes the device type and model, operating system version, IMEI number, language settings, mobile network information, and unique identifiers such as advertising or device IDs.

Log Data

Refers to automatically generated logs from your device when accessing our website, such as IP address, access time, viewed pages, browser type, system activity, and referring website or service.

Location Data

We may collect your real-time location using IP address, GPS, Wi-Fi networks, or other methods to improve service personalization and delivery accuracy.

Aggregate and Anonymous Data

We may also generate and use aggregate data, such as statistical or demographic information, which does not directly or indirectly reveal your identity. This data is anonymized and used for service analysis, system improvement, and business development purposes.

If You Provide Incomplete Personal Data

If we are legally required to collect specific data and you choose not to provide it (or only provide it partially), we may not be able to offer certain features or complete your transaction. This may result in limited access to specific features or services on our platform.

How We Collect Your Personal Data

We may obtain your Personal Data through the following sources:

1. Directly from you 
   When you register an account, fill out a purchase form, participate in promotions, communicate via live chat, or make a payment. This also includes correspondence via email, phone, or web forms.
2. Automatically from Your Device
   When you access our site, we may automatically collect technical and location data through cookies, server logs, or tools like Google Analytics. We use cookies to track user activity and improve your site experience. You may adjust your cookie preferences through your browser settings.
3. From Third Parties
   We may receive your information from service partners such as payment gateways, logistics providers, analytics tools, or social media platforms, as permitted by law. This also includes data from financial institutions when you link or add a payment method.
4. Third-Party Data Provided by You
   If you submit information belonging to another individual (e.g., as a shipping recipient or referral), you are responsible for ensuring that you have obtained the individual’s consent to share their data with us.

How We Use Your Personal Data

We use your Personal Data for various purposes as permitted by applicable laws and regulations (“Purposes”), whether you are a customer (User) or a business partner or service provider (Seller).

If You are a User

We may use your Personal Data to:

• Identify and register you as a User, and to create, manage, and verify your account on our website.
• Provide the services you request, including processing orders, arranging deliveries, and facilitating payments.
• Conduct necessary verification processes, including Know Your Customer (KYC) where applicable.
• Send you notifications related to your transactions, order status updates, and other account activities.
• Manage and store your account information, including features such as Wishlist, Shopping Cart, and Order History.
• Deliver a more personalized user experience, including product recommendations based on your preferences or shopping history.
• Communicate with you for customer support purposes, transaction clarification, or the delivery of important information.
• Respond to your feedback, inquiries, suggestions, or complaints.
• Analyze your shopping behavior and habits to improve our service efficiency and quality.
• Manage your participation in loyalty programs, such as shopping points or discount vouchers.
• Send you marketing content, special offers, surveys, and promotional updates or event announcements (with your consent, where required by law).
  

If You are a Seller

We may use your Personal Data to:

• Register and manage your Seller account on our platform.
• Verify your identity and business eligibility prior to account activation.
• Share orders placed by Users with you, and facilitate communication between you and the buyers.
• Process payments related to your sales and provide transaction history or reporting.
• Send notifications and updates regarding your account, new features, or operational policies.
• Handle complaints submitted by Users related to the services you provide.
• Customize and enhance the platform to meet your needs as a Seller, including tools and features that support your performance.
• Analyze Seller activity and User behavior to inform service improvements and business strategy.
• Manage participation in incentive programs, promotions, or other benefits.
• Send marketing communications or strategic partnership opportunities (with your consent where required by law).

If You are a User, Seller, or Other Party

We may also use your Personal Data more generally to:

• Operate internal business functions and support system development.
• Monitor and improve the performance, security, and functionality of our website.
• Provide technical assistance and resolve operational issues.
• Conduct research and data analysis for service development, commercial collaboration, or strategic partnerships.
• Prevent, detect, and investigate suspicious activities, legal violations, or actions that breach our policies.
• Fulfill legal and regulatory obligations, including audits, reporting, or inspections by relevant authorities.
• Fulfill other purposes that we inform you of, and where required, with your explicit consent.
  

Disclosure of Your Personal Data

In the course of providing our services, your Personal Data may be shared with our affiliates and strategic partners, as long as it is relevant to legitimate purposes and permitted by applicable laws and regulations.

Disclosures may occur under the following circumstances:

• To Sellers (if you are a User), so that the Seller can process and fulfill your order.
• To Users (if you are a Seller), to enable them to transact with you and communicate directly.
• To government institutions or legal authorities, in response to official requests, legal obligations, or investigations.
• In legal proceedings, whether involving a dispute between you and us, or between you and a third party related to our services.
• To third-party service providers, such as payment gateways, logistics providers, data analytics firms, IT services, digital marketing agencies, or integration platforms, for the operational and technical support of Inessa's services.
• In emergency situations, particularly those related to your health or safety, your data may be shared with appropriate authorities to respond to the situation.
• In the context of corporate transactions, such as a merger, acquisition, or asset sale, your data may be part of the transferred assets, while maintaining compliance with applicable privacy standards.
• To collaboration partners, such as those supporting our promotional programs, marketing campaigns, customer surveys, or third-party application integrations, provided they are subject to equivalent data protection and confidentiality obligations.

We do not sell or rent your Personal Data to any party.

If a data disclosure does not directly identify you as an individual, we will first remove or anonymize any personally identifiable information to the greatest extent possible before sharing it.​

Data Security

The security and confidentiality of your Personal Data is a top priority for 33PercentActive. We are committed to implementing reasonable and proportionate administrative, technical, and physical safeguards to protect your Personal Data from unauthorized access, collection, use, disclosure, alteration, or destruction, as well as from accidental loss or damage.

While we continuously strive to maintain the highest level of data security, you should understand that no system or method of data transmission over the Internet is completely secure. Therefore, we cannot guarantee that your Personal Data will be entirely immune to unauthorized access by third parties due to circumstances beyond our control.

You are responsible for maintaining the confidentiality of your account information, including your username, password, and One-Time Password (OTP). We strongly advise that you do not share these details with anyone and that you take appropriate steps to secure the device you use to access our website.

Data Retention

Your Personal Data will be retained by Inessa for as long as necessary to fulfill the purposes for which it was collected, for the duration of our internal data retention policy, or as required by applicable laws and regulations.

Once the data is no longer required—whether because your account has been deleted, your consent has been withdrawn, or the processing purpose has been fulfilled—we will delete or anonymize your Personal Data so that it can no longer be used to identify you.

We may permanently delete your Personal Data under the following conditions:

1. The purpose of collection has been fulfilled and there is no legal basis to retain the data;
2. The applicable retention period has expired; or
   
3. There is no longer any business or legal obligation to retain the data.
   

Please note that in certain circumstances, parts of your Personal Data may continue to be held or managed by third parties, including but not limited to government institutions, in accordance with their own data retention policies. If your data has been shared with a government institution or our official partners lawfully, the storage of your data will be subject to the respective policies of those institutions.

Limitation of Responsibility for Communication Outside Our System​

We recommend that all communication between Users and Sellers be conducted through Inessa’s official system (such as via the live chat feature or confirmation emails). If you choose to communicate directly outside our system—such as through phone calls, text messages, or social media—any risks arising from the processing of Personal Data outside our platform will be solely the responsibility of the parties involved.

33PercentActive is not responsible for any privacy violations or misuse of Personal Data resulting from such interactions outside our official platform.

Disclaimer of Liability

To the extent permitted by applicable law, you expressly release Inessa from any claims, liabilities, losses, costs, or expenses—whether direct or indirect—arising from the misuse of Personal Data that occurs outside our system. This includes, but is not limited to, legal fees and damages caused by unauthorized third-party actions

You may have certain rights under applicable laws and regulations to:

• Access your Personal Data;
• Request correction of your Personal Data; and/or
• Request deletion of your Personal Data that is within our possession or control.

We may reject some or all of your requests if permitted or required by law, including where the Personal Data relates to other individuals, or if the request is deemed irrelevant, excessive, or invalid.

In accordance with applicable laws, we reserve the right to charge an administrative fee for any request to access and/or correct your Personal Data.

Third-Party Websites and Services

The Inessa website and our marketing materials may contain links to third-party websites that are not operated or controlled by us. Any collection and processing of Personal Data on such websites is solely the responsibility of the respective third-party providers.

If you choose to access third-party websites or services through links provided on our site or materials, you are subject to the privacy policies and terms of service of those third parties. Therefore, we strongly recommend that you carefully review their privacy notices before sharing any Personal Data.

Use of Biometric Features on Mobile Devices

If you use fingerprint or facial recognition features on your mobile device to authenticate access to our site or application, please note that we do not store your biometric data. Such data is stored locally on your device or by your device’s operating system provider (e.g., Apple, Samsung, Android), depending on your device settings.

You are fully responsible for the security of your device and the biometric data stored within it. We are not liable for any unauthorized access or loss arising from the misuse of biometric data outside of our system.

Advertising and Promotional Links

Advertisements displayed on our website or application may redirect you to third-party websites. Any data you provide after clicking on an ad will be handled by the respective advertiser and will be subject to their own privacy policy. We have no control over how your data is used once you leave our platform.

Marketing and Promotional Materials

We and our business partners (including vendors, suppliers, or third-party merchants who collaborate with Inessa) may send you marketing and promotional communications in various forms, including but not limited to:

• Email
• App notifications
• Direct messages via chat platforms or social media
• Physical mail or in-app messages

These communications will only be sent if you have given your consent to receive them—for example, by subscribing to our newsletter or opting in to receive special offers.​

You may opt out of receiving marketing communications at any time by clicking the “unsubscribe” link in any message, adjusting your account preferences, or contacting us directly.

Please note that even if you choose not to receive marketing communications, we may still send you non-promotional messages, such as transaction confirmations, account updates, or administrative notices.

Changes to This Privacy Notice

We may update this Privacy Notice from time to time. If there are any material changes, we will notify you via our website, email, or other official communication channels.

By continuing to use our website, application, or services after such changes are announced, you are deemed to have read and agreed to the latest version of this Privacy Notice.

We encourage you to review this page periodically to stay informed about how Inessa collects, uses, and protects your Personal Data.