1. Introduction
This Privacy Policy explains how personal data is processed through the PUMA RAMP environment (the “Platform”).
For privacy inquiries, data-subject requests, support, legal notices or questions concerning the roles described below, users may contact gurkan.can@puma.com.
2. Controller and processor roles
PT PUMA Cat Indonesia acts as the data controller for personal data processed through the Platform.
Retail Ascent acts as the data processor and technology provider on behalf of PT PUMA Cat Indonesia. Retail Ascent processes personal data under the instructions of PT PUMA Cat Indonesia for the purpose of operating, supporting, securing and improving the Platform.
3. Scope
This Privacy Policy applies to authorised users of PUMA RAMP, including:
- employees
- contractors
- administrators
- managers
- store teams
- business partners
- authorised service providers
It applies to personal data processed through:
- web applications
- authenticated modules
- support communications
- uploaded files
- platform-generated activity records
- learning and developmental features
Separate employment policies, internal policies, contracts or notices may also apply in addition to this Privacy Policy.
4. Personal data processed
The Platform may process the following categories of personal data.
A. Account and identity information
- name
- business email address
- employee or user identifier
- job title
- department
- role
- assigned organisation
- assigned store or location
- permission level
- profile information
B. Authentication and security information
- sign-in records
- timestamps
- session information
- authentication events
- access logs
- permission changes
- security events
- device or browser information
- IP address when technically collected
C. Operational information
- assigned actions
- action status
- comments
- approvals
- opportunity records
- Deal Pack information
- store records
- assets
- maintenance information
- work orders
- vendor information
- reports
- uploaded business documents
- workflow history
D. Academy and learning information
- curriculum activity
- course progress
- quiz results
- attendance
- learning submissions
- developmental assessments
- facilitator observations
- capability-development information
- achievement records
E. Communications and support information
- support requests
- feedback
- incident reports
- emails or messages sent regarding the Platform
F. Technical and usage information
- page access
- module usage
- feature interaction
- error logs
- performance records
- audit records
5. Purposes of processing
Personal data may be processed to:
- create and manage authorised accounts
- authenticate users
- apply roles and permissions
- provide access to platform modules
- support retail and business workflows
- manage actions, projects, approvals and operational tasks
- provide learning and capability-development features
- maintain auditability and accountability
- generate authorised business reports
- protect platform and account security
- investigate incidents
- provide technical support
- maintain and improve platform performance
- comply with applicable law
- establish, exercise or defend legal rights
- enforce internal policies and authorised-use requirements
Personal data is not sold to advertisers or unrelated third parties.
6. Lawful basis for processing
Personal data is processed only where an applicable lawful basis exists under Indonesian law and other applicable requirements. Depending on the context, processing may be based on:
- consent
- the performance of employment, contractual or business obligations
- compliance with legal obligations
- legitimate organisational interests
- protection of security and legal rights
- other lawful grounds recognised by applicable law
7. Learning and developmental information
Academy and developmental features may generate learning results, observations, progress information and developmental insights. These features are designed to support learning, coaching and capability development.
Retail Ascent does not make automated hiring, promotion, compensation, disciplinary or termination decisions.
Authorised PT PUMA Cat Indonesia personnel remain responsible for any employment-related review or decision and must apply applicable company policies, human judgement and legal requirements.
8. Automated processing and decision support
RAMP may use rules, scoring, prioritisation, recommendations or automated processing to organise information, support workflows and surface operational or developmental insights.
Such outputs do not independently make final employment decisions. Users should review generated recommendations and remain responsible for final business and people decisions.
10. Service providers
The Platform relies on approved service providers that support operation, security and delivery of the service. Such providers may fall within categories including:
- cloud hosting
- database services
- authentication services
- email delivery
- error monitoring
- document storage
- security services
Service providers act under contractual and confidentiality obligations appropriate to their role.
11. International transfers
Personal data may be processed or stored in locations outside Indonesia where approved infrastructure or service providers operate. Where cross-border processing occurs, PT PUMA Cat Indonesia and Retail Ascent will apply measures required under applicable Indonesian law, including appropriate contractual, organisational and technical safeguards where applicable.
12. Retention
Personal data is retained only for as long as reasonably necessary for the purposes described in this Privacy Policy, including operational, contractual, security, audit and legal requirements. Retention may depend on:
- type of data
- active account status
- employment or business relationship
- tenant instructions
- audit requirements
- legal obligations
- dispute or investigation requirements
When data is no longer required, it may be deleted, anonymised or securely restricted in accordance with applicable requirements.
13. Security
Reasonable organisational and technical measures are used to protect personal data. These may include:
- role-based access
- authentication
- tenant separation
- database access controls
- audit logging
- encrypted network transmission
- controlled administrative access
- monitoring
- backup and recovery measures
No electronic system can be guaranteed to be completely secure. Users must protect their credentials and report suspected unauthorised access to gurkan.can@puma.com.
14. Your rights
Subject to applicable law, individuals may have rights to:
- request information about processing
- request access to personal data
- request correction of inaccurate data
- request completion of incomplete data
- request deletion or destruction where applicable
- withdraw consent where processing depends on consent
- object to or request restriction of certain processing
- object to decisions based solely on automated processing where applicable
- request data portability where applicable
- submit a complaint
- seek remedies available under applicable law
Requests must be sent to gurkan.can@puma.com. Identity may need to be verified before a request is processed. Some requests may be limited where retention or processing is required by law, security, investigation, contractual obligation or legitimate organisational need. You may also review your current account and consent status via Privacy & Data.
16. Children
PUMA RAMP is an enterprise platform intended for authorised business users. It is not designed for use by children. Users must not submit children’s personal data unless specifically authorised and legally permitted.
17. Changes to this policy
This policy may be updated to reflect:
- platform changes
- operational changes
- legal requirements
- security requirements
- processing changes
The page always shows the current effective date. Material changes may be communicated through appropriate internal or platform channels.
18. Contact
Data Controller
Data Processor and Technology Provider
Retail Ascent
Technology service and data processor acting on behalf of PT PUMA Cat Indonesia.