Privacy Policy
Effective from: October 30, 2026
Version: 1.0
INTRODUCTION
This Privacy Policy (the "Privacy Policy" or "Privacy Notice") explains how PT HerLens Tekno Medika ("HerLens", "We", "Us"), a company established under the laws of the Republic of Indonesia, obtains, collects, stores, controls, uses, processes, analyzes, updates, displays, transfers, discloses, and protects your Personal Data in connection with the use of the HerLens mobile application, website, and all related features and services (collectively, the "Platform").
HerLens is a screening aid application for women's reproductive health (cervical cancer screening), intended for use by healthcare professionals in providing services to patients.
This Privacy Policy is intended for, and is provided to, two groups of Personal Data Subjects:
- Healthcare professionals (and partner healthcare facilities) as users of the Platform, whose account Personal Data We process; and
- Patients, whose health data is processed through the Platform by healthcare professionals.
For healthcare professionals, this Privacy Policy is presented and agreed to within the Platform upon registration/use. For patients — who are generally not direct users of the Platform — consent and the privacy notice are delivered by the healthcare professional as part of the informed consent and medical record process already in place at the healthcare facility, prior to the examination. A plain-language summary is available in the Patient-Specific Section at the end of this document as a reference for such delivery. In this Privacy Policy, "You" refers to the relevant Personal Data Subject according to context — the healthcare professional for account Personal Data, and the patient for health data.
This Privacy Policy is prepared with reference to:
- Law No. 27 of 2022 on Personal Data Protection, as amended by Law No. 1 of 2026 (the "PDP Law");
- Government Regulation No. 33 of 2026 on the Implementing Regulation of the PDP Law ("GR 33/2026");
- Law No. 17 of 2023 on Health;
- Minister of Health Regulation No. 24 of 2022 on Medical Records ("MoH Reg. 24/2022"); and
- other relevant implementing and sectoral regulations.
DEFINITIONS
For the purposes of this Privacy Policy:
a. Personal Data means data concerning an identified or identifiable natural person, whether on its own or in combination with other information, directly or indirectly, through electronic or non-electronic systems.
b. Specific Personal Data means Personal Data requiring a higher level of protection, including health data and information, as regulated under the PDP Law.
c. Personal Data Subject means the natural person to whom the Personal Data relates (e.g. the healthcare professional user and the patient).
d. Personal Data Controller means the party that determines the purposes of, and exercises control over, the processing of Personal Data.
e. Personal Data Processor means the party that processes Personal Data on behalf of the Personal Data Controller.
f. Data Protection Officer (DPO) means the official or officer carrying out the data protection function as regulated under the PDP Law.
g. Applicable Laws and Regulations means all laws, government regulations, ministerial regulations, and other legal provisions in force in Indonesia from time to time during the term of this Privacy Notice.
h. You refers to the relevant Personal Data Subject according to context — the healthcare professional for account Personal Data, and the patient for health data.
i. Platform, We/Us, and other capitalized terms have the meanings defined elsewhere in this Privacy Policy.
ACKNOWLEDGMENT AND CONSENT
Consent is obtained and recorded through two mechanisms, according to the role of the Personal Data Subject:
A. Consent of the Healthcare Professional (Account User)
Upon registration and/or first use of the Platform, the healthcare professional provides consent by ticking the consent box (checkbox) and pressing the "I Agree" button for this Privacy Policy together with the Terms and Conditions. This affirmative action is recorded by the system along with a timestamp and the policy version as proof of consent (Article 24 of the PDP Law). This consent covers the processing of the healthcare professional's account Personal Data as described in this Privacy Policy. If the healthcare professional does not provide consent, an account cannot be created or activated.
B. Consent of the Patient (Health Data Subject)
Because the patient is not a direct user of the Platform, the patient's consent is obtained by the healthcare professional as part of the informed consent (medical consent) and medical record process already in place at the healthcare facility, in accordance with Article 293 of Law No. 17 of 2023 and MoH Reg. 24/2022. That process must include an explanation that examination data and images are recorded, analyzed using an artificial intelligence aid, and stored as part of the medical record.
Before entering or uploading patient data, the healthcare professional must provide confirmation (attestation) within the Platform that the patient has been given an explanation and has provided their consent. This confirmation is recorded by the system along with a timestamp as proof (Article 24 of the PDP Law). HerLens does not issue a separate consent form; proof of patient consent takes the form of the informed consent record held at the healthcare facility (managed by the facility as Controller) and the attestation recorded within the Platform.
C. Representation and Warranty of the Healthcare Professional
By entering patient data into the Platform, the healthcare professional represents and warrants that the consent referred to in letter B has been lawfully obtained and recorded before the data is entered, and that adequate explanation has been given to the patient. The healthcare professional and/or healthcare facility is fully responsible for obtaining and retaining such patient consent, and shall hold HerLens harmless from third-party claims arising out of any failure to obtain such consent.
D. Material Changes
In the event of material changes to this Privacy Policy, We may request renewed consent (a checkbox for healthcare professionals) and/or update the patient consent mechanism (attestation within the Platform and/or the healthcare facility's informed consent process). Consent to a previous version is not deemed to automatically apply to material changes.
1. SUMMARY
This summary is provided for ease of understanding and is not a substitute for the full content of the Privacy Policy.
- We collect healthcare professionals' (account) Personal Data and, through them, patient health data including cervical examination images.
- The artificial intelligence (AI) analysis result is a screening aid, not a diagnosis.
- There is no solely automated decision-making. The final clinical decision is always made by a healthcare professional.
- Medical record data is stored within the territory of Indonesia. Where there is processing by service providers that may involve locations outside Indonesia, We apply safeguards in accordance with the PDP Law and GR 33/2026 (see Section 9).
- We do not sell Personal Data.
- Consent is obtained through two mechanisms: healthcare professionals via a checkbox in the Platform; patients via the healthcare facility's informed consent process, confirmed by the healthcare professional in the Platform prior to the examination (see the Acknowledgment and Consent section).
- You have rights as a Personal Data Subject, including the rights of access, rectification, erasure, and withdrawal of consent (see Section 13).
- We appoint a Data Protection Officer (DPO) whom You may contact (see Sections 14 and 19).
2. ROLES AND RESPONSIBILITIES OF THE PARTIES
Because the Platform is used by healthcare professionals on patients, the data processing roles are as follows:
a. For user (healthcare professional) account data, PT HerLens Tekno Medika acts as the Personal Data Controller.
b. For patient (health) data, the healthcare facility and/or the healthcare professional entering the data acts as the party that determines the purpose of the service and is authorized to obtain patient consent, while We process such data to provide the Platform's services. The detailed allocation of roles (Controller/Processor or Joint Controllers) is set out in a Cooperation Agreement and Data Processing Agreement (DPA) covering scope, data categories, purpose, duration, the parties' rights and obligations, and audit rights, in accordance with GR 33/2026.
c. The healthcare professional must obtain the patient's consent (informed consent) through the healthcare facility's informed consent process and provide confirmation within the Platform as described in the Acknowledgment and Consent section, letter B, before collecting, entering, uploading, or processing patient data and images through the Platform, in accordance with applicable medical records and medical confidentiality rules. The detailed obligations of healthcare professionals are set out in Section 12.
3. TYPES OF PERSONAL DATA
We may collect the following types of Personal Data, including but not limited to:
a. User Identity and Account Data (healthcare professional): name, email address, phone number, password and PIN (stored in protected/encrypted form), and role/account type.
b. Patient Health Data (constituting Specific Personal Data), entered by the healthcare professional, including:
- i. date of birth;
- ii. reproductive history (gravida, parity, abortus);
- iii. contraception history (pill, injection, IUD, implant, sterilization, condom);
- iv. prior screening history (date, result, notes);
- v. reported complaints/symptoms;
- vi. cervical examination images;
- vii. examination code, examination status, and examination notes;
- viii. AI analysis results, comprising the confidence score and system classification (normal/abnormal);
- ix. the healthcare professional's diagnosis, recorded separately from the AI result.
c. Technical and Usage Data: access tokens and refresh tokens stored encrypted on the device, creation and update timestamps, app preferences (e.g. language), and device permissions you grant (e.g. camera for capturing examination images).
Personal Data does not include information that is lawfully available in the public domain.
4. HOW WE COLLECT PERSONAL DATA
a. Directly from You (healthcare professional), when you register, create an account, set a PIN, or update your profile.
b. From healthcare professionals, when patient data and images are entered into the Platform as part of an examination. We obtain patient data indirectly through healthcare professionals; the healthcare professional/healthcare facility is responsible for providing notice to and obtaining consent from the patient in accordance with Applicable Laws and Regulations.
c. Automatically from the device, such as authentication tokens, timestamps, and app preferences, when you use the Platform.
5. HOW WE USE PERSONAL DATA
We use Personal Data for the following purposes (the "Purposes"), including but not limited to:
a. registering, verifying, and managing user accounts;
b. providing examination, image analysis, and history storage functions;
c. displaying screening results to healthcare professionals;
d. securing accounts through authentication, PIN, and tokens;
e. maintaining, fixing, and improving the quality and security of the Platform;
f. complying with legal and regulatory obligations, including medical records rules; and
g. communicating with you regarding the service.
We do not use patient data to train or develop artificial intelligence models without a valid legal basis and adequate anonymization/de-identification measures.
6. LEGAL BASIS FOR PROCESSING
We process Personal Data on one or more of the following legal bases set out in Article 20 of the PDP Law:
a. the consent of the Personal Data Subject for one or more specific Purposes;
b. the performance of a contract or fulfilment of your request;
c. compliance with a legal obligation of the Personal Data Controller;
d. protection of the vital interests of the Personal Data Subject, including health interests; and/or
e. other legitimate interests, having regard to the rights of the Personal Data Subject.
For Specific Personal Data (patient health data), processing by Us as a Processor rests on the basis of the provision of healthcare services and compliance with medical record obligations by the healthcare facility, with the patient's informed consent obtained by the healthcare professional as set out in the Acknowledgment and Consent section, letter B.
7. PROCESSING BY ARTIFICIAL INTELLIGENCE (AI)
a. Cervical image analysis is performed by Our own artificial intelligence model through an application programming interface (API). For analysis purposes, examination images are transmitted to and processed on Our backend servers located in Indonesia. This processing does not involve any third-party AI provider.
b. The AI result is a preliminary classification and confidence score that serves as a screening aid and is not a diagnosis.
c. There is no solely automated decision-making producing legal effects or a significant impact on the patient. The final clinical decision is always made by a qualified healthcare professional. You have the right to object to solely automated decision-making (see Section 13).
d. Because the processing of health images is classified as high-risk, We carry out a Data Protection Impact Assessment (DPIA) for this AI feature (see Section 16).
8. DISCLOSURE OF PERSONAL DATA
We do not sell Personal Data. We may disclose Personal Data on a limited basis to:
a. service providers/Personal Data Processors that help operate the Platform, including cloud storage/computing providers and backend infrastructure. In accordance with MoH Reg. 24/2022, the storage of medical records on cloud-based media is carried out only with providers that are certified in accordance with applicable laws and regulations, and bound by a data processing agreement requiring data protection;
b. law enforcement or competent authorities, where required by Applicable Laws and Regulations or a court order; and
c. relevant healthcare facilities for continuity of care, within the scope of authority.
Service providers may only process Personal Data in accordance with Our instructions and for the specified Purposes, and are bound by confidentiality and security obligations equivalent to this Privacy Policy.
9. DATA STORAGE AND TRANSFER
a. Examination and account data are stored on Our backend servers and cloud storage. Authentication tokens are stored encrypted on the device (secure storage).
b. In-country storage for medical records. Data constituting medical records (including cervical examination images and patient health data) is stored in certified data centers/cloud storage located within the territory of Indonesia, in accordance with applicable medical records rules.
c. Transfer outside the territory of Indonesia. To the extent there is any processing or storage of Personal Data (other than medical records that must be stored in-country) involving a location or recipient outside Indonesia, We take the following steps in accordance with the PDP Law and GR 33/2026:
- i. mapping and minimizing the transfer (purpose, data types, and recipients);
- ii. assessing the legal instrument and the risks to the Personal Data Subject together with mitigation measures;
- iii. informing the Personal Data Subject of the transfer, the protection instrument, and the associated risks; and
- iv. ensuring the transfer rests on one of the following bases: (1) the country/recipient is on a list of countries with an equal or higher level of protection; (2) there is an adequate and binding safeguard (e.g. standard contractual clauses); or (3) the explicit consent of the Personal Data Subject.
10. DATA RETENTION
a. We retain Personal Data only for as long as necessary to fulfil the processing Purposes or as required by Applicable Laws and Regulations, with the following periods:
- i. Patient medical record data (including examination images): at least 25 (twenty-five) years from the date of the last visit/examination, in accordance with MoH Reg. 24/2022; thereafter it may be destroyed, except for data still in use;
- ii. Healthcare professional account data: for as long as the account is active and up to 24 (twenty-four) months after the account is closed, unless a longer period is required by law;
- iii. Technical/log data: 12 (twelve) months for security and audit purposes.
b. After the retention period ends or consent is withdrawn (insofar as not conflicting with legal obligations), We will delete or anonymize the Personal Data.
11. DATA SECURITY
We apply reasonable technical and organizational safeguards, including but not limited to encrypted token storage on the device, token-based (Bearer) authentication with a refresh mechanism, role-based access control, activity logging, and data transmission over encrypted channels (HTTPS).
However, no system is completely secure. You are responsible for keeping your account credentials (password/PIN) confidential.
12. MEDICAL CONFIDENTIALITY AND HEALTHCARE PROFESSIONAL OBLIGATIONS
Health data is treated as confidential information. As an inseparable part of the Cooperation Agreement, every healthcare professional/healthcare facility using the Platform must:
a. obtain the patient's consent through the healthcare facility's informed consent and medical record process (which includes an explanation that examination data and images are recorded, analyzed using an AI aid, and stored) before collecting, entering, or uploading patient data and images; provide confirmation of such consent within the Platform; and retain the informed consent record as proof of consent (Article 24 of the PDP Law);
b. maintain the confidentiality of medical records and use patient data only for legitimate healthcare purposes;
c. not store or disseminate patient Personal Data (whether general or specific) on personal devices or other storage media beyond what is necessary for examinations on the Platform;
d. not disclose patient Personal Data to any other party, including for law enforcement purposes, without a lawful basis and without written consent/notice from the management of the healthcare facility in accordance with applicable procedures; and
e. maintain the confidentiality of account credentials and promptly report any suspected misuse of access.
Breach of these obligations may result in termination of access and legal liability in accordance with the agreement and Applicable Laws and Regulations.
13. YOUR LEGAL RIGHTS
Under the PDP Law, a Personal Data Subject has the right to:
a. obtain information about the identity, legal basis, and Purpose of processing;
b. access and obtain a copy of their Personal Data;
c. correct and/or update inaccurate Personal Data;
d. terminate processing, delete, and/or destroy their Personal Data as permitted;
e. withdraw consent to processing;
f. object to solely automated decision-making;
g. suspend or restrict processing proportionately;
h. claim and receive compensation for processing violations; and
i. obtain and/or use their Personal Data in a portable format (data portability), where technically feasible.
To exercise these rights, contact Us via Section 19. We will acknowledge receipt of a request within 3 × 24 hours and resolve it within no more than 14 (fourteen) business days, which may be reasonably extended with notice, and will treat your request/complaint confidentially. For patient data, requests may be submitted through the relevant healthcare professional/facility. Fulfilment of the right to erasure of patient data remains subject to medical record retention obligations (Section 10).
14. DATA PROTECTION OFFICER (DPO)
In accordance with the PDP Law and GR 33/2026, because Our core activities involve the large-scale processing of Specific Personal Data (health data), We appoint a Data Protection Officer (DPO) responsible for providing compliance advice, monitoring the implementation of the PDP Law and internal policies, overseeing the conduct of DPIAs, and serving as the point of contact for Personal Data Subjects and competent authorities.
DPO contact:
- Name/Title: [DPO name/title]
- Email: dpo@herlens.id
15. PERSONAL DATA BREACH NOTIFICATION
In the event of a personal data protection failure (data breach) that gives rise to risk or harm, We will provide written notification to the Personal Data Subject and the competent authority within 3 × 24 hours (72 hours) of becoming aware of and confirming such failure, in accordance with Article 46 of the PDP Law and GR 33/2026. The notification will include, at a minimum, the Personal Data affected, the chronology, the impact assessment, and the remediation steps.
16. DATA PROTECTION IMPACT ASSESSMENT (DPIA) AND RECORD OF PROCESSING ACTIVITIES (RoPA)
a. We carry out a Data Protection Impact Assessment (DPIA) for high-risk processing activities, including AI analysis of health images, before such activities are undertaken.
b. We maintain a Record of Processing Activities (RoPA) in accordance with GR 33/2026, covering, among other things, the identity of the Controller/Processor, data sources, legal basis and purposes, retention periods, security measures, and transfer details.
17. HOW TO REQUEST ACCOUNT DELETION
You may request deletion of your account and related Personal Data by contacting Us at privacy@herlens.id. We will process such requests in accordance with applicable rules, while observing legal obligations to retain medical records. Deletion of patient data may be subject to the authority of the relevant healthcare facility.
18. UPDATES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. Material changes will be notified through the Platform and/or Our official channels, with an updated effective date.
19. HOW TO CONTACT US
For questions, Personal Data Subject requests, or privacy complaints, contact:
PT HerLens Tekno Medika
- Data Protection Officer (DPO): dpo@herlens.id
- Address: Infiniti Office, Menara Cakrawala 12th Floor, Unit 05A, Jl. M.H. Thamrin No. 9, RT. 002 RW. 001, Kota Administrasi Jakarta Pusat, DKI Jakarta, 10340, Indonesia
We will contact you within a reasonable time and treat your complaint confidentially.
20. LANGUAGE
This Privacy Policy is made in Indonesian and English. In the event of any difference or conflict of interpretation between the two versions, the Indonesian version prevails.
PATIENT-SPECIFIC SECTION — PLAIN-LANGUAGE PRIVACY NOTICE FOR PATIENTS
This section is an inseparable part of this Privacy Policy and serves as a plain-language summary delivered by the healthcare professional to the patient as part of the informed consent process. For the full terms, the entire content of this Privacy Policy applies. In this section, "You" means the patient.
Who we are. HerLens is a screening aid application for cervical cancer, used by your healthcare professional. We process your data on behalf of the healthcare facility/healthcare professional treating you.
What data is processed about you. Date of birth; reproductive and contraception history; screening history; complaints; cervical examination images; artificial intelligence analysis results (confidence score and normal/abnormal classification); and the healthcare professional's diagnosis.
What it is for. To help the healthcare professional perform cervical cancer screening, store the examination history, and comply with medical record obligations. The artificial intelligence analysis result is only an aid, not a diagnosis — the clinical decision is always made by the healthcare professional, and no decision is made solely by a machine.
Where it is stored and how it is secured. Your medical record data is stored within the territory of Indonesia with technical safeguards (including encryption during data transmission).
With whom it is shared. The relevant healthcare facility; technology service providers that help operate the system (bound by confidentiality obligations); and competent authorities where required by law. We do not sell your data.
How long it is kept. Medical records are kept for at least 25 years from your last visit, in accordance with applicable regulations.
Your rights. You have the right to access, rectify, erase (insofar as not conflicting with medical record retention obligations), restrict or object to processing, withdraw consent, object to solely automated decision-making, and claim compensation for violations. To exercise these rights, contact your healthcare professional/healthcare facility, or Our Data Protection Officer (DPO) at dpo@herlens.id.
Your consent. By giving your consent to the examination process (informed consent) at the healthcare facility, you agree to the screening procedure and the processing of personal data as described above. Consent may be withdrawn at any time, provided that medical record retention remains subject to legal obligations.
STATEMENT OF CONSENT (HEALTHCARE PROFESSIONAL)
BY TICKING THE CONSENT BOX AND PRESSING THE "I AGREE" BUTTON, I DECLARE THAT I HAVE READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS PRIVACY POLICY AND ITS CONSEQUENCES, AND ACCEPT EACH OF THE RIGHTS, OBLIGATIONS, AND TERMS SET OUT HEREIN. THIS STATEMENT IS DEEMED TO BE MY CONSENT AS A PERSONAL DATA SUBJECT AND/OR AN AUTHORIZED PARTY.