Privacy Statement (ID)
Last Updated : January 14, 2022
This policy will be effective starting from Monday 17 January 2022
To view previous revisions, please click here
Estimated reading time : 25 minutes
- “PopIt Snack Account” means an alphanumeric code issued by the Site Manager and may be associated with a unique name (or have another synonym such as “username”), to identify the user in using the Site Services.
- “Site Manager” means the company PT. Mandiri Tunggal Sejahtera Berkarya as the owner, manager, controller of the PopIt Snack Site.
- “Electronic Document” means any User’s Electronic Information, including but not limited to electronic contracts, which are created, forwarded, transmitted, received, or stored in electronic form.
- “Electronic Information” means one or a set of electronic data belonging to the User, including but not limited to writing, sound, pictures, maps, designs, photographs, electronic data interchange (EDI), electronic mail (e-mail), telegram, telex, telecopy or the like, processed letters, signs, numbers, access codes, symbols, or perforations that have meaning or can be understood by people who are able to understand them.
- “Services ” means all services provided by the Site Manager to its Users.
- “User” means any natural person, partnership, firm, company, legal entity, ministry, agency or organization that uses the Site Services.
- “Site” means the Service which may take the form of a Site page that refers to the PopIt Snack Platform, its derivative sites including but not limited to derivatives of popitsnack.com, and the PopIt Snack mobile application.
- “Application” means the Site Services in the form of mobile or web-based applications (mobile apps and web apps).
- “PopIt Snack Sites and Applications” means all Services that are in the form of web pages or mobile or web-based applications (mobile apps and web apps).
- “Electronic Certificate” means a Certificate issued by the Site Manager which is electronic in nature and contains an Electronic Signature and identity indicating the legal subject or the parties to the Electronic Transaction.
- “Services Policy” means any other Policy Document that informs the Site’s Service policies and practices.
- “Company Partner” means a partnership, firm, company, legal entity, ministry, agency or organization that relies on the Site Services.
- “Electronic Signature” means a Signature consisting of Electronic Information that is attached, associated or related to other Electronic Information used as a verification and authentication tool made for the purposes of the Site Services.
The Site Manager is subject to and complies with the applicable laws and regulations in carrying out the Security Commitment as an Electronic System Operator and the Communication Data Recording Policy for the use of Personal Data, processing and storage processes which are regulated in the documents on the Site page that have been published by Site Manager.
Compliance with laws and regulations in other jurisdictions is regulated in Site Manager Compliance in other languages according to their territories.
C. Use of the Site
You as a User and accessor of this Site are not allowed to reproduce, distribute, display, sell, rent, transmit, create derivative works from, translate, modify, reverse engineer, disassemble, describe or exploit this site or any part of it, unless expressly permitted. by us in writing or electronically.
The content provided on this site is for informational purposes only. Uploads in the form of “Posts“, or “Comments“, or “Opinions” on this site may be made by other Users and do not reflect the opinion of the Site Manager. We are not responsible or liable for any claims, damages or losses caused by the User from the use of the Site or the materials contained therein.
Accordingly, You agree that you will not assist others to transmit, upload, transmit, distribute, store, create or use this Site for the purposes of the following activities:
- Content that threatens, incites, harasses, incites, or advocates harassment of others, or interferes with other Users’ use of the Site.
- Content that encourages all forms of criminal acts that violate local, regional, national or international laws or regulations. This applies to laws governing intellectual property and other proprietary rights.
- Impersonate, act, or portray yourself as another person or entity or business.
- Create obscene, vulgar, offensive, defamatory, deceptive, false or pornographic related content.
- Sending advertisements, promotional materials, emails, spam, viruses and other forms.
- Use the Service for commercial or non-personal purposes.
- Collects User’s personal information from this Site without permission.
- Plan, operate any kind of damage by uploading viruses, worms or other malicious code.
- Sell or transfer your account, including all or part of a User profile to items related to the Service.
Violating any of the above provisions may constitute a crime under applicable law and we may report such violations and disclose your identity to the appropriate authorities. Other matters regarding the above are summarized in the Community Policy and its disclosure before the applicable law in accordance with the regulations for Electronic System Operation and the Customer Data and Transaction Security Policy.
D. Personal Data
1. Acquisition of Personal Data
By mechanism and stages the Site Manager is permitted and can obtain and process User’s personal data, especially when the User submits an application for the Service, and through the acquisition of this Personal Data it is obtained directly from the User, then the Site Manager will carry out the process of verifying the User’s Personal Data for the suitability of the data provided by the User, and finally send it to the data center authority for processing. If the Service application process is stopped by the User, the Site Manager will not store the User’s Personal Data. This refers to the Data Communication Recording Policy.
The Site Manager collects User Personal Data with the aim of processing and validating User activities, managing and expediting the process of using the Site, as well as other purposes as long as permitted by applicable laws and regulations. The User data collected is as follows:
- Electronic Data and/or Electronic Information submitted independently by the User, including but not limited to data submitted when the User:
- Create or update a PopIt Snack Account, or Electronic Information, or Electronic Documents, including User name (including username), email address, phone number, password, address, photo, and other information that can identify Users;
- Contacting the Site Manager, including through customer service;
- Fill out a survey sent by the Site Manager or other parties officially appointed to represent the Site Manager;
- Interact with other Users through message features, product discussions, reviews, ratings, and other interactive features (either one-way or two-way) contained on the Site;
- Use the services on the Site, including detailed transaction data, including the type, amount and/or description of the product or service purchased, delivery address, payment channel used, transaction amount, transaction date and time, and other transaction details;
- Fill in payment data when the User performs payment transaction activities through the Site, including but not limited to bank account data, credit cards, virtual accounts, instant payments, internet banking, retail outlets; and/or
- Using the features and services of the PopIt Snack Site and Application which requires access permission to the relevant data stored in the User’s device.
- Electronic Data and/or Electronic Information recorded when the User uses the Site, including but not limited to:
- Real or approximate location data such as IP address, Wi-Fi location and geo-location ;
- Data in the form of time from each User activity in connection with the use of the Site, including registration, login and transaction times;
- User’s usage data or preferences, including User interactions in using the Site, saved choices, and selected settings. The data is obtained using cookies, pixel tags and similar technologies that create and maintain a unique identifier;
- Device data, including the type of device used to access the Site, including hardware model, operating system and version, software, IMEI number, file name and version, language selection, unique device identifier, advertising identifier, serial number, device movement information, and/or cellular network information; and/or
- Data records (logs), including records on servers that receive data such as device IP addresses, access dates and times, application features or pages viewed, application work processes and other system activities, browser type, and/or sites or services third parties that the User uses before interacting with the Site.
- Electronic Data and/or Electronic Information obtained from other sources, including but not limited to:
- Data in the form of geo-location (GPS) from Company Partners who help the Site Manager in developing and providing services on the Site to Users, including payment service providers, logistics or courier partners, site infrastructure, and other partners.
- Data in the form of email, phone number, name, gender, and/or date of birth of the Company Partner where the User creates or accesses a PopIt Snack Account, such as social media services, or sites/applications that use the application programming interface (API) of the Site and the PopIt Snack Application. or used by the Site Manager;
- Data from financial service providers, including but not limited to credit rating agencies or bureaus or Credit Information Management Agencies (LPIP);
- Data from financial service providers (if the User uses specific features such as applying for a loan through the Site Manager’ Site or Application); and/or
- The data is in the form of an email from a marketing service provider.
2. Use of Personal Data
Examples of Electronic Data and/or Electronic Information required when a User requests a PopIt Snack Account are:
- NIK number
- TIN Number
- Full name
- Place and date of birth
- Email address
- Mobile phone number
Site Managers can combine data obtained from these sources with other data they have for updating User information, as described in article D number 1 above.
Site Manager may use Electronic Data and/or Electronic Information obtained and collected from Users as mentioned in the previous section for the following matters:
- Process all forms of requests, activities or transactions made by Users through the Site, including for the purpose of sending products to Users.
- Provision of features to deliver, deliver, maintain and improve products and services, including:
- Offer, obtain, provide, or facilitate services such as the home page, search, search, advertising, product recommendations, insurance, financing, loans, or other products through the Site;
- Allows features to personalize User accounts, such as Shopping Cart, Wishlist; and/or
- Carry out internal activities necessary to provide services on the PopIt Snack Site and Application, such as troubleshooting software problems, bugs, operational issues, conducting data analysis, testing, and research, and to monitor and analyze usage trends and activities.
- Assist Users when communicating with PopIt Snack Customer Service, including but not limited to:
- Check and resolve User issues;
- Direct User inquiries to appropriate customer service personnel to resolve issues;
- Monitor and improve PopIt Snack customer service response;
- Contacting Users via email, letter, telephone, fax, and other communication methods, including but not limited to assisting and/or completing the transaction process or problem solving process, as well as delivering news or other notifications in connection with the protection of User’s Personal Data by the Site Manager, including failure of protection of User’s Personal Data;
- Using Electronic Data and/or Electronic Information obtained from Users for research, analysis, product development and testing purposes in order to improve the security of services on the Site, as well as develop new features and products; and
- Inform Users regarding products, services, promotions, studies, surveys, news, latest developments, events and other information, either through the Site or through other media. Organizers may also use this information to promote and process contests and sweepstakes, award prizes and serve relevant advertisements and content about the PopIt Snack Service and Company Partners.
- Monitor or investigate suspicious transactions or transactions indicated to contain elements of fraud or violations of the Terms and Conditions or other applicable legal provisions, as well as take necessary actions as a follow-up to the results of monitoring or investigating the transaction.
- In certain circumstances, theSite Manager may need to use or disclose the User’s Personal Data for law enforcement purposes or to fulfill the requirements and obligations of the applicable laws and regulations, including in the event of a dispute or legal process between the User and the Site Manager, or suspected criminal acts such as fraud. or data theft.
- Facilitate merger transactions, sale of company assets, consolidation or restructuring, financing or acquisitions involving the Site Manager.
3. Personal Data Storage
The Site Manager stores User’s personal data and protects it from loss, misuse or improper disclosure, in accordance with Information Security Management System practices. This storage will continue for as long as the User’s PopIt Snack Account is still valid, as well as the data retention period specified in the Site Manager CP and CPS documents.
The implementation of Information Security is carried out based on the criteria of SNI ISO/IEC 27001, namely Governance, Risk Management, Framework, Asset Management, Technological Aspects with the supplement of Securing the Engagement of Third Party Service Providers, Security of Cloud Infrastructure Services and Protection of Personal Data. The matter regarding the storage of personal data is in accordance with the KAMI Index as determined by law, and with this, the User also understands that the Storage of Personal Data on the Company’s Partners has been published in the Service Level Agreement (SLA), Operational Level Agreement (OLA), and Acceptable Usage Policy (AUP). These efforts and implementations are;
- The Site Manager takes security and storage efforts with great care in order to protect the confidentiality of the User’s personal data from time to time.
- The Site Manager guarantees that any data uploaded and sent by the User to the Service will be stored securely and sent confidentially using information security standards.
- The Site manager guarantees to protect the user’s private key repository securely with a high level of security (escrow), namely that the user’s private key can only be accessed by the user, using 2 factor authentication .
- The Site Manager will deliver notifications to Users in bulk in the event that there is a failure to protect the confidentiality of the User’s personal data in the Operation of the PopIt Snack Electronic System in accordance with the provisions of the applicable laws and regulations.
- The Site Manager guarantees that only the Site Manager can view the Electronic Data and/or Electronic Information that the User uploads through the User’s PopIt Snack Account to the Site Services and other parties that the User gives permission to access the Electronic Data and/or Electronic Information of the User.
4. Disclosure of Personal Data
Site Managers may use or disclose User’s Personal Data including Electronic Data and/or Electronic Information belonging to Users in the context of complying with legal and statutory provisions, in the context of law enforcement processes or taking further preventive action in connection with unauthorized activities, alleged acts of crime. criminal offense or violation of law or statutory regulations. In connection with the use or disclosure, the User releases and releases the Site Manager from all claims, demands, damages that may arise in connection with the use or disclosure.
- The Site Manager is committed to maintaining the confidentiality of User Personal Data which is under the control of the Site Manager and guarantees that there is no disclosure, sale, transfer, distribution and/or borrowing of User Personal Data to other third parties, without the consent of the User, except in the following cases:
- It is necessary to disclose User Personal Data to Company Partners or other third parties who assist the Site Manager in providing available services or services that will later be available on the Site and process all forms of User activities on the Site, including processing transactions, payment verification, promotions, and product delivery.
- The Site Manager may provide User Personal Data to the Company Partner in accordance with the User’s agreement to use the Company Partner’s services, including other applications or sites that have integrated their API or services, or Company Partners with which the Site Manager has collaborated to organize promotions, competitions, or special services. available on the Site.
- There is a need for communication between Company Partners (such as logistics, payment providers, and providers of features or other service facilities) and Users in terms of resolving problems or other matters.
- Site Managers can provide User Personal Data to vendors, consultants, marketing partners, research firms/institutions, or similar service providers in the context of marketing activities carried out by third parties, improving and maintaining the service quality of the PopIt Snack Site and Application, as well as other publication activities.
- Users contact the Site Manager through public media such as blogs, social media, and certain features on the Site, where communication between the User and the Site Manager can be seen and known by the general public.
- Site Manager may share User Personal Data with its subsidiaries and affiliates to help provide services or perform data processing for and on behalf of Site Manager.
- The Site Manager may disclose and/or provide User’s Personal Data to interested parties in the context of carrying out the User’s creditworthiness analysis.
- The Site Manager discloses User Personal Data in an effort to comply with legal obligations and/or a valid request from law enforcement officials or authorized state administration agencies.
5. Personal Data Deletion
In case of User deletion of personal data, the customer terminates access to PopIt Snack Account and terminates the Service. Personal data in the form of Electronic Data and/or Electronic Information will be stored by the Site Manager for a retention period of 1 (one) year as stated in the CP CPS Root CA Indonesia document or if required for legal purposes, the retention period of 1 (one) year will be suspended and procedural exceptions are; stored indefinitely.
The Site Manager will retain information as long as the User’s account remains active and can perform deletion in accordance with the provisions of the applicable legal regulations.
Security, Storage and Deletion of User’s Personal Data
- The Site Manager protects each User’s Personal Data stored in its system, and protects such data from unauthorized access, use, modification, retrieval and/or disclosure by using a number of security measures and procedures, including passwords and User OTP (One Time Password) codes.
- Although the Site Manager has used its best efforts to secure and protect User’s Personal Data, please note that the transmission of data over the Internet is never completely secure. Thus, the Site Manager cannot guarantee 100% security of the data provided or sent to the Site Manager by the User and the provision of information by the User is at the User’s own risk.
- Site Manager will delete and/or anonymize User Personal Data that is under the control of Site Manager if (i) User Personal Data is no longer needed to fulfill the purpose for which it was collected; and (ii) retention is no longer required for the purpose of compliance with applicable laws and regulations.
- Please note that there is still a possibility that some User’s Personal Data is stored by other parties, including authorized state administration agencies. In the event that we share User’s Personal Data with authorized state administration agencies and/or other agencies that may be appointed by the competent government or have cooperation with the Site Manager, the User agrees and acknowledges that the storage of User’s Personal Data by the agency will follow the respective data retention policies. – each of these agencies.
6. Consent to the Use of Personal Data and its Protection
a. That the User hereby declares that he has given explicit permission to the Site Manager prior to the issuance process of the User’s PopIt Snack Account.
b. In using the PopIt Snack Account and the Service, the User agrees to comply with all laws and regulations in the applicable jurisdiction where the PopIt Snack Account or Service is accessed or used.
c. Site Manager takes reasonable steps to ensure that User’s Personal Data is processed accurately and completely. However, it is important for the User to notify the Site Manager in a timely manner about any changes to the User’s Personal Data or if there are errors in the User’s Personal Data or User Electronic Data and/or User Electronic Information which are under the control of the Site Manager.
e. The Site Manager may charge an administrative fee to the User to handle User’s request to access or correct the User’s Personal Data.
g. The matter regarding User’s request to access User’s Personal Data on the PopIt Snack Site, has also been regulated in part of the application of Good Corporate Governance principles, namely Transparency, Accountability, Responsibility, Independent, and Fairness. In this case, it refers to Public Transparency and includes the company’s Whistleblowing System.
7. Contacts and Notifications/Notifications
a. Every notification from the Site Manager addressed to the User or User will be announced through the Site and sent via electronic mail (e-mail) or Short Message Service (SMS) to the User registered with the User’s Account.
b. Every notification from a User or User addressed to the Site Manager becomes effective when the notification is received by the Site Manager through the electronic mail address email@example.com and/or through physical documents sent to PT. Mandiri Tunggal Sejahtera Berkarya.
G. Purchase Policy
When placing an order you indicate a desire to purchase the product and are subject to the following terms and conditions. All orders are subject to availability and price confirmation at the time of transaction. Delivery times may vary according to availability and any representations made for delivery times are within the area specified by us and are subject to delays due to postal delays or force majeure for which we will not be liable. Please see the Shipping Policy section.
For a contract with the Site Manager you must be able to make legal and sufficient payments for us to make through legal channels. Site Manager reserves the right to refuse requests made by Users. If the User’s order is received, We will notify the User via e-mail that the User’s order is placed in our system and is waiting for payment. We will also inform in the same e-mail the appropriate payment details and methods. When placing your order make sure all the details you provide to us are true and accurate, that you are an authorized user of the credit/debit card or bank account used to place your order, and that there are sufficient funds to cover the cost of your order. Product and service costs may fluctuate.
Site Manager may make changes or updates the Purchase Policy from time to time. The Site Manager suggests that Users read carefully and check every page of the “Online Shopping” terms which include the Purchase Policy, Payment Policy, Shipping Policy, Return Policy, and other policies related to this from time to time to find out any changes. By continuing to access and use the Site and the Site Manager Application and other PopIt Snack Services, the User is deemed to have agreed to the changes in these policies.
H. Sales Contract
When you place an order, you will receive an acknowledgment confirmation e-mail containing Electronic Data and/or User Electronic Information that has received your order and that your order is waiting for payment or which is on the Order Confirmation page when making online shopping transactions. Please note that this acknowledgment email will only be an acknowledgment of you and not a finalization of your order or the formation of a sales contract from the Site Manager to you as a User. A sales contract will not be formed until we send confirmation by e-mail that your payment has been received and that the goods you ordered will be delivered to you. Only the items listed in the e-mail sent, which are also referred to as Electronic Data and/or User Electronic Information,
I. Pricing and Availability
While we do our best to ensure that all product details, descriptions, availability, and prices that appear on this site are accurate, errors may occur from time to time. If we discover an error in the price or availability of an item you ordered, we will notify you of this immediately and give you the option of reconfirming your order at the correct price or canceling it. If the Site Manager is unable to contact you or receive an acknowledgment of your transaction, we will treat the transaction as a Canceled Order.
If you cancel an order and you have already paid for the transaction, you will not receive a refund. All charges and shipping costs will be charged and other additional costs as stated on the Order Confirmation page when making a transaction; Such additional costs will be clearly displayed and applicable and included in the total cost prior to placing your order.
This is regulated in the discussion regarding the Transaction Security Protocol Diagram in accordance with the Electronic System Operation on the Customer Data and Transaction Security page.
Upon receipt of your order, an e-mail notification will be sent to you to confirm receipt and detailed payment of your transaction. Once we have received the transaction funds from you and your payment has been confirmed, we will send you a notification e-mail indicating that your order will be dispatched soon. Your order will then be dispatched within 1-2 business days of the acknowledgment e-mail/notification e-mail.
K. Discount Code
Discount codes – Discount Codes may from time to time be offered to PopIt Snack Account holders;
- The code can only be applied to purchases made through the above account where the discount code is offered and registered. Account discount code so it won’t be transferred.
- Promotional discount codes – We may from time to time offer promotional discount codes which may apply in the case of any, or certain specified, purchases made though this Site.
L. Content Removal
This site has the right to remove or return content posted by you if we believe that it violates our guidelines, such as content that is inaccurate, obscene, vulgar, offensive, libelous, fraudulent, false, pornographic related, or is considered spam. We have no obligation to maintain or provide copies of any content, nor do we guarantee confidentiality with respect to your content.
M. Copyright and License
All content included on this Site, such as text, graphics, logos, button icons, images, audio clips, digital downloads, data compilations, and software, is the property of PT. Mandiri Tunggal Sejahtera Berkarya or its licensors and is protected by applicable and international copyright laws. The compilation of all content on this Site is the exclusive property of PT. Mandiri Tunggal Sejahtera Berkarya and protected by local and international copyright laws. All software used on this Site is the property of PT. Mandiri Tunggal Sejahtera Berkarya or software supplier and is protected by applicable and international copyright laws. All these rights are protected by PT. Mandiri Tunggal Sejahtera Berkarya and its license. you can save, print and display content provided for your personal use only. You are not permitted to publish, manipulate, distribute or otherwise reproduce, in any format, any of the content or copies of the content provided to you or appearing on this Site or you may use such content in connection with a business, commercial company or third party.
You will not modify, translate, reverse, decompile, disassemble or create derivative works based on the software or accompanying documentation provided by PT. Mandiri Tunggal Sejahtera Berkarya or its licensee.
If you believe that anything on the Site violates any copyright that you own or control, you may file a notice of such infringement with the Site Manager.
N. Your Account
When you register for the Service, you may be asked to provide a password for your unique name. We strongly recommend that you keep your passwords confidential at all times.
We reserve the right to suspend your account and/or require you to change your password if we believe for any reason that your password is no longer secure. We are not responsible for any loss or damage arising from the loss of passwords.
You are responsible for maintaining the confidentiality of your account and password and for restricting access to your computer, and you agree to accept responsibility for all activity that occurs under your PopIt Snack Account. If you are under 16 years of age, you may use the Site only under the supervision of a parent or guardian. The Site Manager has the right to refuse service, terminate PopIt Snack Account, delete or edit content, or cancel orders at its discretion without prior notice to you.
O. Third Party Sites, Linked Sites, Products and Services
This site may contain links to other third party sites (“Linked Sites”). We do not control or operate any of the Linked Sites, and you agree that we are not responsible for the content and your use of such Linked Sites. Access and use of Linked Sites, including information, materials, products and services or available through Linked Sites is solely at your own risk.
In any case where you are dealing with other businesses or third parties found through this Site or Linked Sites, these transactions are only between you and the other party. You agree that we are not responsible or liable for any loss or damage whatsoever arising as a result of any such transaction or as a result of the presence of third parties such as on this Site.
- Cookies are small files that will automatically take place on the User’s device that performs the function of saving User preferences and configurations while visiting a site.
- These cookies are not intended to be used when accessing other data that the User has on the User’s computer, other than what the User has agreed to submit.
- The Site Manager may uses the Google Analytics Demographics and Interest feature. Data that Site Manager obtains from these features, such as age, gender, User interests and other information that can identify Users, will be used by Manager for the development of features, facilities, and/or content contained on the Site. If the User does not want his data to be tracked by Google Analytics, the User can use the Google Analytics Opt-Out Browser Add-On.
- Site Managers can use the features provided by third parties in order to improve the services and content of the Services, including among others the assessment, adjustment, and serving of advertisements to each User based on interests or history of visits. If the User does not want ads to be displayed based on these adjustments, then the User can set it through the browser/browser.
- More detailed information and descriptions are set out in the Cookies Policy.
Q. Applicable Law
1. Complaints regarding User Data Protection
- If the User has concerns about the Management’s handling or treatment of User’s Personal Data or if the User believes that his privacy has been violated, the User can contact the Site Manager through PopIt Snack customer service or to the PopIt Snack contact page listed on this Site by explaining the identity and nature of the User’s complaint.
- The Site Manager will investigate User complaints and endeavor to provide a response to the complaint within a reasonable time after receiving the complaint submitted by the User.
S. Linking to Our Page
Links to our page (https://popitsnack.com) and derivatives thereof are allowed, provided linking is done so in a fair and legal manner and does not damage our reputation or take advantage of it, but you may not build links in a way that suggests any form of association, approval, or support on our part if it is not yet in official writing.
You may also not build links from websites that you do not have direct ownership of.
The Site and Site Services may not be framed on any other site, nor may you create a link to any part of this Site other than the home page. We reserve the right to withdraw linking permissions without prior notice to you.
Q. Risk of Loss
All items purchased from this Site are manufactured in accordance with a delivery contract. This means that the risk of loss and title for the item may pass to you upon our delivery to the freight forwarder.
U. Ownership of Trademarks, Names and Images of Persons, Third Party Copyrights
All persons (including names and images), third party trademarks and images of third party products, services, or locations displayed on this site are in no way associated or affiliated with PopIt Snack®, unless otherwise expressly stated in the Brand Usage Policy or Disclaimer. Any trademarks/names displayed on this site are owned by their respective trademark owners. Where a trademark or brand name is referred to, it is only used to describe or identify the products and services and is in no way a representation that the product or service is endorsed by or linked to the Site.
W. Retention of Rights