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PT SPACE DRAGON BALI PRIVACY NOTICE

Last updated: August 2024

This privacy notice of PT Space Dragon Bali (“we,” “us”, “our” or the “Company”), describes how and why we might collect, store, use, disclose, transfer, and/or protect (“process”) your Personal Data when you use our services (“Services”), such as when you:

  • visit our website at [https://www.anantaradragon.com], or any website of ours that links to this privacy notice;
  • accept cookies when accessing our website at [https://www.anantaradragon.com], or any website of ours that links to this privacy notice;
  • voluntarily complete a customer survey, provide your feedback either on the website or via email or subscribe for our newsletters and event notifications;
  • contact us by phone or text, or when you visit our offices; and
  • interact with us in other related ways, including any sales, marketing, or events,

Privacy Notice

In this context, personal data means any individual’s or person’s data that can be identified on its own or in combination with other information either directly or indirectly through an electronic or non-electronic system as defined in Law Number 27 of 2022 on Personal Data Protection (“Personal Data”).

Please take a moment to familiarize yourself with our Privacy Notice to help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [info@ anantaradragon.com].

This Privacy Notice explains on:

1. WHAT PERSONAL DATA DO WE COLLECT?

2. HOW DO WE PROCESS YOUR PERSONAL DATA?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL DATA?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

6. HOW DO WE KEEP YOUR PERSONAL DATA SAFE?

7. DO WE COLLECT INFORMATION FROM MINORS?

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. DO WE DO CROSS-BORDER DATA TRANSFER?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO WE MAKE UPDATES TO THIS PRIVACY NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT PERSONAL DATA DO WE COLLECT?

Personal information you disclose to us

In Short: We collect Personal Data that you provide to us.

We collect Personal Data that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Data Provided by You. The Personal Data that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The Personal Data we collect may include the following:

  • full name;
  • phone numbers;
  • email addresses;
  • address;
  • country of residence;
  • date of birth;
  • personal identification documentation, such as your passport, ID card or other documentation required by Indonesian law;
  • payment details;
  • survey information (your comments and responses, etc. to market surveys, contests and promotional offers conducted by us or on our behalf); and/or
  • website and communication usage (details of your visits to our websites or social media platforms collected through cookies or other tracking technologies, including behavioural information, browser details, Internet Protocol (“IP”) addresses, purchasing history, location information, etc.)

Specific (Sensitive) Personal Data. We do not process specific Personal Data, e.g., biometric data, medical records, etc., as determined in Law Number 27 of 2022 on Personal Data Protection (“PDP Law”).

All Personal Data that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such Personal Data by referring to Section 13 of this Privacy Notice.

Data automatically collected from your device by using our Service.

In Short: Some information — such as your IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring Uniform Resource Locator (“URL”), device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. We may use external web analytics services to collect the above information.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use Global Positioning System (“GPS”) and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR PERSONAL DATA?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with applicable laws and regulations. We may also process your information for other purposes with your consent.

We process your Personal Data for a variety of reasons, depending on how you interact with our Services, including:

  • to provide the Services to you, including identification and verification of your identity, negotiating, execution and performance of agreements, contracts with you, processing of payment for any of the Services provided to you (unless otherwise governed under a specific privacy notice);
  • to provide customer support (such as responding to your enquiries, and communicating with you by email, letter, telephone, or other means);
  • for marketing purposes (such as providing you with news, latest offers and promotions or marketing communications, where you have chosen to receive these);
  • for analytics and profiling (for analysis of consumption needs, preferences, interests);
  • to improve our Services;
  • for safety and security purpose; and
  • for legal and administrative purposes (to comply with applicable laws and regulations, court order or any requirements of relevant government authorities; to establish legal claims or defenses; to obtain legal advice; to exercise and/or protect our rights).

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL DATA?

In Short: We only process your Personal Data when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under the PDP Law and its implementing and related regulations, like with your consent, to comply with the applicable laws and regulations, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, to fulfill our legitimate business interests, or to accommodate vital and public interests.

The PDP Law requires us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your Personal Data if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
  • Contractual Obligations. We may process your Personal Data in order to negotiate, enter into or fulfill a contract with you as well as to keep records for accounting purposes after the termination of the contract with you.
  • Legal Obligations. We may process your Personal Data where we believe it is necessary for compliance with our regulatory and legal obligations, including our ‘know your customer’ (KYC) and due diligence requirements, cooperation with a law enforcement body or regulatory agencies, exercising or defending our legal rights, disclosure your information as evidence in litigation in which we are involved and/or for tax purposes when we act as a tax withholder.
  • Legitimate Interests. We may process your information to prevent fraud or to ensure the network and information security of our IT systems.
  • Vital Interests. We may process your Personal Data if circumstances risk your life in the Company’s properties, e.g., natural disaster, personal injury, etc.
  • Public Interests. We may process your information if circumstances necessitate your Personal Data being processed by the authorized governmental authority, e.g., for immigration purposes, etc.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We will only transfer Personal Data to third parties where we have the legal right to do so. In order to preserve the Personal Data and ensure that our Personal Data protection, confidentiality, and security requirements are met when we share data with others, we put in place contractual agreements and security methods as necessary.

We may need to share your Personal Data in the following situations in which as examples of Personal Data processing activities in which case we will need to transfer your data to a third party or such processing activities are performed by a third party as data processors:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company subject to the procedures as governed under the applicable laws and regulations (including the PDP Law);
  • Service providers.  We may share your information with our agents, banks, contractors or third party service providers which provide administrative, marketing, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to support the provision of the Services (including operations of our business and perform activities on our behalf); and/or
  • Advisors. We may share your information with our advisors (e.g., legal, financial, business or other advisors) who are under a duty of confidentiality to us.  

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Noticeunless otherwise required by law.

We will only keep your Personal Data for as long as it is necessary for the purposes set out in this Privacy Notice, in a minimum of five years, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR PERSONAL DATA SAFE?

In Short: We aim to protect your Personal Data through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any Personal Data we process: your personal data is securely stored on a cloud basis storage namelyMicrosoft Azur.

When we share your Personal Data with any third parties, we will strive to ensure that such third parties comply with this Privacy Notice and other appropriate confidentiality and security measures that we require them to comply with when using your Personal Data, except for the Personal Data you provide directly to the third parties through the use of their services.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your Personal Data, transmission of Personal Data to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that Personal Data from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [info@anantaradragon.com]

8. WHAT ARE YOUR PRIVACY RIGHTS?

We would like to make sure you are fully aware of all of your data protection rights. You are entitled to the following rights:

  • The right to be informed – request to know. Depending on the circumstances, you have a right to know:
    • whether we collect and use your personal data;
    • the categories of personal data that we collect;
    • the purposes for which the collected personal data is used;
    • whether we share personal data to third parties;
    • the categories of personal data that we shared, or disclosed for a business purpose;
    • the categories of third parties to whom the personal information was shared, or disclosed for a business purpose;
    • the business or commercial purpose for collecting or sharing personal information; and
    • the specific pieces of personal information we collected about you.
  • The right to access – You have the right to request the Company for access/copies of your personal data.
  • ‍The right to rectification – You have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete the information you believe is incomplete.
  • ‍The right to erasure – You have the right to request that the Company terminate the data processing or erase/destroy your personal data to the extent permissible under prevailing laws and regulations.  If you ask us to delete your personal data, we will respect your request and delete your personal information, subject to certain exceptions provided by the laws and regulations, such as (but not limited to) our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
  • The right to restrict processing – You have the right to request that the Company restrict/delay/suspend the processing of your personal data to the extent permissible under prevailing laws and regulations.
  • The right to object to the processing – You have the right to object to the Company’s processing of your personal data to the extent permissible under prevailing laws and regulations.
  • The right to data portability – You have the right to request that the Company transfer the data that we have collected to another organization, or directly to you to the extent permissible under prevailing laws and regulations.
  • The right to withdraw consent – You have the right to withdraw your personal data processing to the extent permissible under the applicable laws and regulations.
  • The right to obtain compensation – You have the right to submit a claim and obtain compensation for the violation of personal data processing under the applicable laws and regulations.

By sending an email to [info@ anantaradragon.com], you can exercise the above rights, and we will respond to you subject to the applicable laws and regulations as well as in a timely manner.

9. DO WE DO CROSS-BORDER DATA TRANSFER?

The Company complies with laws on the transfer of Personal Data between countries to help ensure your data is protected, wherever it may be. In any case, we will take appropriate steps to ensure that your Personal Data remains subject to a standard of protection comparable to the requirements under the applicable laws and regulations.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

11. DO WE MAKE UPDATES TO THIS PRIVACY NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws and regulations in Indonesia.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?

If you have questions or comments about this notice, you may email us at [info@anantaradragon.com] or contact us by post at:

[The Promenade Jl. Shortcut Teratai - Batu Bolong No. P14, Canggu, Kuta Utara, Badung, Bali , Indonesia]

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the PDP Law, you may have the right to request access to the Personal Data we collect from you, change that information, or delete it. To request to review, update, or delete your Personal Data, please write to us at [info@anantaradragon.com].