Paradygma Privacy Statement

Last updated: June 23, 2025

Welcome to the Paradygma e-learning showcase platform (lms.paradygma.co.id). This Site is owned and operated by PT Paradygma Kreasi Nawasena ("we," "us," "our"). We are an digital content services company, and this Moodle-based site is designed to demonstrate our products and services to prospective and current clients ("you", “your”).

We takes your privacy seriously. We will not sell, lease, or exchange your personal data to, or otherwise share your personal data with, third parties in ways other than described in this Privacy Statement.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you are granted access to and use our demonstration Site. We are committed to protecting your privacy and handling your data in an open and transparent manner.

1. Applicability

By accessing or using this Site, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with the terms, please do not access the Site.

For the purpose of data protection regulations, Paradygma is the Data Controller of the personal data collected through this Site.

2. Information We Collect

To provide you with access to our e-learning showcase, we may collect the following personal information:

(i) Information You Provide to Us

To provide you with access to our e-learning showcase, we may collect the following personal information:

Identity and Contact Data: Your full name, email address, job title, and the name of your company or organization.
Account Credentials: A username and a password (which is stored in a hashed, non-readable format).

(ii) Information We Collect Automatically as You Use the Site

As you interact with our demonstration content, our Moodle platform automatically logs information about your activity. This includes:

E-learning Activity Data: Records of the demonstration courses you access, the resources you view (e.g., videos, documents), your progress through modules, and any interactions with sample activities like quizzes or forums.
Log and Usage Data: Your Internet Protocol (IP) address, login dates and times, browser type and version, operating system, and a log of your general activity on the Site (e.g., pages visited).
Cookies and Similar Technologies: We use cookies that are essential for the Moodle platform to function correctly, such as session cookies to keep you logged in. For more information, please see Section

3. How We Use Your Information

We use the information we collect for the following legitimate business purposes:

To Provide and Manage Your Access: To create and maintain your user account and allow you to log in and explore our e-learning content.
To Demonstrate Our Product Capabilities: Your interaction with the Site helps us showcase the functionality and quality of our e-learning solutions.
For Business Development and Communication: Our sales or marketing teams may use your contact information and activity data (e.g., which content you viewed) to have more relevant follow-up conversations with you about our products and services.
To Improve Our Products and Services: We analyze aggregated and anonymized usage data to understand which demonstration content is most effective and popular, helping us improve our offerings.
To Ensure Security and Maintain the Site: To monitor for and prevent security breaches, troubleshoot technical issues, and ensure the Site is operating correctly.
To Comply with Legal Obligations: To fulfill any legal or regulatory requirements.

4. Legal Basis for Processing (for EEA/UK Users)

If you are from the European Economic Area (EEA) or the UK, our legal basis for collecting and using the personal information described above will depend on the information concerned and the specific context. We will normally collect personal information from you only:

Where we have your consent to do so (e.g., for creating your account and for marketing communications).
Where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (e.g., for analyzing usage to improve our products and for business development follow-up).

5. How We Share Your Information

We do not sell your personal data. We only share your information with the following parties under limited circumstances:

Internally: Your information is accessible to authorized Paradygma personnel (e.g., in sales, marketing, and IT departments) who need access to perform their job functions.
Third-Party Service Providers: We may share information with vendors who perform services for us, such as cloud hosting providers that host this Moodle site. These providers are contractually obligated to safeguard your data and are not permitted to use it for their own purposes.
Third-Party Platform: Where you access the Services through a third-party platform or where you download the Services as an app, you will be subject to the terms of use and privacy policy of that third-party platform, and you should also review those terms carefully. Any Information collected by these third parties is not governed by this Privacy Policy but by the privacy policy, if any, of such third party. If you have questions about a third party’s information practices, please read its privacy policy. We assume no responsibility or liability whatsoever for the practices, actions, or policies of such third parties, and We are not responsible for the content or privacy practices of such online sites.
Legal Requirements: We may disclose your information if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
Business Transfers: In the event of a merger, acquisition, or asset sale, your information may be transferred to the new entity.

6. Data Security

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. This includes data encryption, access controls, and regular security assessments. However, please remember that no electronic transmission or storage technology can be guaranteed to be 100% secure.

Our website may contain links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for such other websites or third parties’ privacy practices. We encourage you to be aware when you leave our website and read the privacy statements of each website that may collect personal information.

7. Data Retention

We will retain your personal data for as long as is necessary for the purposes set out in this Privacy Policy. Generally, this means we will keep your account information for the duration of our business discussions or until you request its deletion. We may also delete accounts after a prolonged period of inactivity (e.g., 18 months) after notifying you.

8. Cookies

Our Moodle site uses cookies. These are small text files placed on your computer to help the site provide a better user experience. We use:

MoodleSession: An essential cookie you must allow into your browser to provide continuity and maintain your login from page to page.
MOODLEID: A cookie that remembers your username within the browser. This makes returning to the site more convenient.

You can manage cookies through your browser settings, but please note that disabling the MoodleSession cookie will prevent you from being able to log in and use the Site.

9. Your Data Protection Rights

Depending on your location, you have certain rights regarding your personal information. These may include the right to:

The right to access – You have the right to request Paradygma LMS for copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that Paradygma LMS correct any information you believe is inaccurate. You also have the right to request Us to complete information you believe is incomplete.
The right to erasure – You have the right to request that Paradygma LMS erase Your personal data, under certain condition.
The right to restrict processing – You have the right to request that Paradygma LMS restrict the processing of your personal data under certain conditions.
The right to data portability – You have the right to request that Paradygma LMS transfer the data that we have collected to another organization, or directly to you, under certain conditions.
The right to object to processing – You have the right to object to Paradygma LMS processing of your personal data under certain conditions.

To exercise any of these rights, please contact us at halo@paradygma.co.id.

10. Children's Privacy

This demonstration Site is intended for a business-to-business audience and is not directed at individuals under the age of 18. We do not knowingly collect personal information from children.

11. Changes to This Privacy Policy

By accessing or using the Services, you agree to the terms of this Privacy Policy. This is Our entire and exclusive Privacy Policy, and it supersedes any earlier version.

We may update this Privacy Policy from time to time. The updated version will be indicated by a revised "Last Edited." We encourage you to review this policy frequently to be informed of how we are protecting your information.

12. Legal disclosure

We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at halo@paradygma.co.id.

If you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the EEA, you may find the contact details for your appropriate data protection authority on the following website.