Aggregate Data Rights

In this clause:

You

means the brand holding an account on Mula and bound by these Terms.

We

means PT Nara Inovasi Indonesia.

Brand Data

means data you enter or upload to Mula, including product descriptions, component data, material composition, claims and their evidence tiers, supporting documents, images, and maker records together with their attestations.

Scan Events

means the record that a passport page was opened through a QR scan or through the resolver, together with the chapter opened and the time it happened. Scan Events are recorded without accounts, without browsing history, and without device profiles.

Aggregate Data

means derived statistics computed from Brand Data, from Scan Events, or from both, covering more than one brand and presented in a form that does not reveal the identity of any brand, product, maker, or device.

De-identified

means that all direct identifiers have been removed and the result cannot be returned to its source data by reasonable effort.

You remain the owner of Brand Data. This clause transfers no ownership, gives us no right to sell Brand Data, and does not reduce your right to request an export of your own component data as CSV within the 90 day window after the agreement ends.

The licence in 14.3 is granted over use in aggregated and de-identified form only. Beyond that form, we acquire no rights in Brand Data other than those needed to operate the service for you.

You grant us a non-exclusive, royalty free licence, lasting for as long as the Aggregate Data concerned is in use, to use Brand Data and Scan Events in aggregated and de-identified form for the following four purposes, and for these four purposes only:

1. The sector baseline, meaning a picture of the state of the Indonesian textile and fashion sector assembled from data arriving through Mula;
2. Anonymous benchmarking, meaning showing a brand holding a passport where it stands against benchmark data;
3. Research we publish, including research reports and whitepapers; and
4. Development and improvement of the service.

This licence is not transferable, except as part of a transfer of the whole Mula business to a successor bound by this clause on the same terms.

The following limits are binding parts of this clause, not statements of intent. We do not do the following on any surface, including the application interface, public passport pages, the marketing site, reports, the export pack, the API, and our own marketing material.

1. No publication or licensing of identifiable data. We do not publish, licence, sell, or hand to any third party data at an identifiable brand, product, supplier, or maker level. What appears publicly at brand level is only what you yourself publish through your passport pages.
2. Minimum cell size of five. Any cell in Aggregate Data computed from fewer than five units is not displayed. Where exactly one cell falls below five, the next smallest cell is also withheld, because without that the withheld cell can be recovered by subtraction. This limit applies without exception, including to the landing page aggregate block.
3. Every aggregate figure states its coverage. An aggregate figure always carries a statement of how many units it was computed from, expressed as counts and never as a percentage. A figure computed across a set with gaps is not a total and is never presented by us as one.
4. Scans are not people. We do not render a scan count as a number of people, in any language and on any surface. The lawful units are scans for events and unique devices for devices. This limit applies equally to Mula describing itself.
5. Benchmarking is passport against passport only. Benchmarks are built from passport against passport, on the same method and the same completeness, and are visible only to brands holding a passport. A brand is shown how it stands against benchmark data, and is never shown the position of a named competitor.
6. Scanned-label aggregates are a convenience sample. Aggregates computed from labels scanned by consumers report the sample collected, and never characterise the catalogue of a named company. A statement such as “from 40 items scanned” is a lawful form; a share figure about a brand's full catalogue derived from scans is not.
7. Mula describes labels, not brands. No surface of ours classifies a named brand as fast fashion, unsustainable, or any equivalent.
8. Scan data is not a product line. We do not sell competitive panel data and do not accept research commissions about brands that are not our customers.
9. Maker data is not aggregate fodder. The name of a person under 18 is never recorded as an individual and never appears anywhere, including inside aggregates. A maker record enters a calculation only while your attestation over that record remains valid. Withdrawal of a maker's consent or of an attribution takes effect on the public passport page within 24 hours, and the withdrawn record is removed from the next aggregate calculation.
10. Not used to train AI models. We do not use Brand Data or Scan Events to train artificial intelligence models, whether our own or a third party's.
11. No re-identification. We do not attempt to return Aggregate Data to its source data, and do not combine it with third party data in order to identify a brand, product, maker, or device again.

Scan Events are recorded without consumer accounts, without history, and without device profiles. Unique device counts use a rotating, non-reversible identifier. We do not retain the IP address of a scanner, do not form any identifier linking one device across two brands' passports, and hold no per scanner record in any form.

We process anonymous events and do not operate consumer profiles. This clause must not be read as a statement that we compile personal data about the consumers who scan passport pages.

After the agreement ends, your Brand Data stops entering new Aggregate Data calculations.

Aggregate Data already published before the agreement ended, including figures already carried in a research report or whitepaper in circulation, stands as published. That Aggregate Data is de-identified and carries no identity of yours, and a figure already published cannot be recalled from the hands of its readers. This is stated here so that it is clear from the outset, and not as an exception surfacing later.

→ 6. Retention and Deletion of Data, in the additional privacy notice clauses

The purposes listed in 14.3 are a closed set. Adding a new purpose, or relaxing any limit in 14.4, does not apply to you unless we notify you in writing beforehand and you are given the opportunity to end the agreement without penalty if you do not accept it.

This clause governs the use of data in aggregated and de-identified form. It does not reduce data subject rights under Law Number 27 of 2022 on Personal Data Protection, and does not reduce the provisions on retention, deletion, complaint channels, and data subject rights set out in our privacy notice. Where this clause and the privacy notice conflict on personal data, the privacy notice prevails.