Privacy Policy

1. Introduction

PT. Solusi Proda Indonesia ("Proda," "we," "us," or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website at www.prodaidn.com, mobile application, and related services (collectively, the "Service").

This Privacy Policy complies with Indonesian data protection laws, including UU No. 27 Tahun 2022 tentang Pelindungan Data Pribadi (Personal Data Protection Law), UU No. 19 Tahun 2016 tentang Perubahan atas UU No. 11 Tahun 2008 tentang Informasi dan Transaksi Elektronik (ITE Law), and related implementing regulations.

We take your privacy seriously and want to assure you: Proda will NEVER share, sell, rent, or disclose your personal information or business data to any third party without your explicit permission, except as required by Indonesian law or as strictly necessary to provide the Service to you.

2. Data Controller Information

The data controller responsible for your personal data is:

3. Information We Collect

3.1 Personal Information You Provide

When you register for and use the Service, we collect the following personal information that you voluntarily provide:

• Account Information: Name, email address, phone number, password, company name, and job title
• Profile Information: Profile photo, bio, and other optional profile details
• Payment Information: Billing address, payment method details (processed securely by third-party payment processors)
• Business Data: Property listings, transaction records, client information, documents, photos, and other content you upload to the Service
• Communications: Messages, support inquiries, and feedback you send to us
• Identity Verification: Government-issued identification documents if required for certain features or compliance purposes

3.2 Information Automatically Collected

When you access and use the Service, we automatically collect certain technical and usage information:

• Device Information: IP address, browser type, operating system, device identifiers, and mobile network information
• Usage Data: Pages visited, features used, time spent on the Service, search queries, and interaction with content
• Location Data: Approximate geographic location based on IP address (precise location only with your permission)
• Cookies and Similar Technologies: Information collected through cookies, web beacons, and similar tracking technologies
• Log Data: Server logs including access times, error reports, and system activity

3.3 Information From Third Parties

We may receive information about you from third parties, including:

• Payment Processors: Payment confirmation and transaction details
• Analytics Providers: Aggregated usage statistics and performance data
• Social Media: Public profile information if you connect your social media accounts
• Business Partners: Information from authorized business partners or affiliates with your consent

4. How We Use Your Information

We use the collected information for the following purposes, in accordance with Indonesian data protection law:

4.1 To Provide and Maintain the Service

• Create and manage your Account
• Process transactions and manage subscriptions
• Provide customer support and respond to inquiries
• Enable core features such as property management, transaction tracking, and reporting
• Store and sync your data across devices
• Generate PDF brochures, spreadsheets, and marketing materials

4.2 To Improve and Develop the Service

• Analyze usage patterns and trends
• Test and develop new features and functionality
• Monitor and improve performance, security, and reliability
• Conduct research and analytics
• Fix bugs and troubleshoot technical issues

4.3 To Communicate With You

• Send transactional emails (account notifications, payment receipts, security alerts)
• Provide customer support and respond to your requests
• Send service updates and announcements
• Send marketing communications (only with your consent, and you can opt-out anytime)
• Request feedback and conduct surveys

4.4 For Security and Fraud Prevention

• Detect and prevent fraud, abuse, and unauthorized access
• Verify user identity and prevent multiple account creation
• Monitor compliance with our Terms and Conditions
• Protect the security and integrity of the Service
• Investigate and respond to security incidents

4.5 For Legal Compliance

• Comply with applicable Indonesian laws and regulations
• Respond to legal requests from government authorities
• Enforce our Terms and Conditions and other policies
• Protect our legal rights and interests
• Fulfill tax and accounting obligations

5. Legal Basis for Processing (Under Indonesian Law)

We process your personal data based on the following legal grounds under Indonesian data protection law:

• Consent: You have given explicit consent for processing your personal data for specific purposes
• Contract Performance: Processing is necessary to perform our contract with you (providing the Service)
• Legal Obligation: Processing is required to comply with Indonesian legal obligations
• Legitimate Interests: Processing is necessary for our legitimate business interests, provided these do not override your fundamental rights
• Public Interest: Processing is necessary for tasks carried out in the public interest

6. How We Share Your Information

WE WILL NEVER SELL, RENT, OR SHARE YOUR PERSONAL INFORMATION OR BUSINESS DATA WITH THIRD PARTIES FOR THEIR MARKETING PURPOSES WITHOUT YOUR EXPLICIT PERMISSION.

We only share your information in the following limited circumstances:

6.1 With Your Consent

We will share your information with third parties when you explicitly authorize us to do so.

6.2 Service Providers

We work with trusted third-party service providers who help us operate and improve the Service. These providers have access to your information only to perform specific tasks on our behalf and are obligated to protect your information. These include:

• Cloud Hosting Providers: For data storage and server infrastructure
• Payment Processors: To process payments securely (they receive payment information directly)
• Email Service Providers: To send transactional and marketing emails
• Analytics Services: To understand Service usage (using anonymized or aggregated data)
• Customer Support Tools: To provide efficient customer service
• Security Services: To protect against fraud and security threats

All service providers are contractually required to protect your data and use it only for the specific purposes we authorize.

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred to the successor entity. We will notify you of any such change and provide you with choices regarding your information.

6.4 Legal Requirements

We may disclose your information if required to do so by Indonesian law or in response to valid legal requests from government authorities, including to:

• Comply with court orders, subpoenas, or other legal processes
• Respond to requests from law enforcement or government agencies
• Enforce our Terms and Conditions and other policies
• Protect our rights, property, and safety or those of our users and the public
• Detect, prevent, and address fraud, security, or technical issues

6.5 Aggregated and Anonymized Data

We may share aggregated or anonymized information that cannot reasonably be used to identify you, such as statistical data about Service usage, for research, marketing, or business purposes.

6.6 Within Your Organization

If you use the Service as part of a team or organization, your information may be accessible to other authorized users within your organization according to the permissions you or your organization administrator set.

7. Data Security

We implement comprehensive technical, administrative, and physical security measures to protect your personal data from unauthorized access, disclosure, alteration, and destruction. Our security practices include:

• Encryption: Data is encrypted in transit using SSL/TLS and at rest using industry-standard encryption algorithms
• Access Controls: Strict access controls ensure only authorized personnel can access personal data on a need-to-know basis
• Authentication: Strong password requirements and secure authentication mechanisms
• Network Security: Firewalls, intrusion detection systems, and regular security monitoring
• Regular Audits: Periodic security audits and vulnerability assessments
• Staff Training: Regular training of our staff on data protection and security practices
• Incident Response: Documented procedures for detecting and responding to security incidents
• Secure Development: Security best practices in software development and deployment

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your Account credentials.

In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant Indonesian authorities in accordance with Indonesian data protection law.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by Indonesian law.

8.1 Retention Periods

• Account Data: Retained for the duration of your Account plus a reasonable period afterwards (typically 90 days) to allow for Account reactivation
• Business Data: Retained while your Account is active and for up to 90 days after Account deletion, unless you request earlier deletion
• Transaction Records: Retained for at least 10 years to comply with Indonesian tax and accounting laws
• Communications: Customer support inquiries retained for 3 years
• Legal Records: Records related to legal disputes retained until resolution plus applicable statute of limitations
• Technical Logs: Server logs and usage data retained for up to 12 months

8.2 Deletion of Data

After the applicable retention period, we will securely delete or anonymize your personal data. You may request earlier deletion of your data by contacting us, subject to our legal obligations to retain certain information.

9. Your Rights Under Indonesian Law

Under Indonesian data protection law, you have the following rights regarding your personal data:

9.1 Right to Access

You have the right to request access to your personal data and obtain information about how we process it. You can view most of your data through your Account settings.

9.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data. You can update most information directly in your Account settings.

9.3 Right to Erasure

You have the right to request deletion of your personal data, subject to certain legal exceptions (e.g., data we must retain for legal or accounting purposes).

9.4 Right to Restriction

You have the right to request restriction of processing of your personal data in certain circumstances.

9.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.

9.6 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes or based on legitimate interests.

9.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing before consent was withdrawn.

9.8 Right to Lodge a Complaint

You have the right to lodge a complaint with the Indonesian data protection authority if you believe your rights have been violated.

9.9 How to Exercise Your Rights

To exercise any of these rights, please contact us at hello@prodaidn.com. We will respond to your request within the timeframe required by Indonesian law (typically within 30 days). We may request verification of your identity before processing your request.

10. International Data Transfers

Your personal data is primarily stored and processed in Indonesia. However, some of our service providers may be located in other countries. When we transfer your personal data outside Indonesia, we ensure appropriate safeguards are in place to protect your data in accordance with Indonesian data protection law, including:

• Using service providers that comply with internationally recognized data protection standards
• Implementing contractual clauses that require adequate data protection measures
• Obtaining your explicit consent where required by law
• Ensuring the receiving country has adequate data protection laws

We will always prioritize data storage and processing within Indonesia where feasible and will obtain your consent before transferring sensitive personal data outside Indonesia.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, analyze usage, and improve the Service.

11.1 Types of Cookies We Use

• Essential Cookies: Necessary for the Service to function properly (e.g., authentication, security)
• Functional Cookies: Remember your preferences and settings
• Analytics Cookies: Help us understand how users interact with the Service
• Marketing Cookies: Used to deliver relevant advertisements (only with your consent)

11.2 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies. However, this may prevent you from using certain features of the Service. You can manage your cookie preferences through your browser settings or through our cookie consent tool when you first visit our website.

11.3 Third-Party Tracking

We use third-party analytics services such as Google Analytics to collect and analyze usage information. These services may use cookies and similar technologies. You can opt out of Google Analytics by installing the Google Analytics opt-out browser add-on.

12. Children's Privacy

The Service is not intended for children under the age of 18. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately. If we discover that we have collected personal data from a child under 18 without parental consent, we will delete that information promptly.

13. Third-Party Links and Services

The Service may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to third-party services. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services you visit or use.

When you publish property listings to external websites or platforms through our Service, those platforms will have their own privacy policies governing how they handle your information.

14. Marketing Communications

With your consent, we may send you marketing communications about new features, promotions, surveys, and other information that may be of interest to you. You can opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Adjusting your email preferences in your Account settings
• Contacting us at hello@prodaidn.com

Please note that even if you opt out of marketing communications, we will still send you transactional and service-related messages (e.g., Account notifications, security alerts, payment receipts) that are necessary for the Service.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated Privacy Policy on our website with a new "Last Updated" date
• Sending you an email notification (for significant changes)
• Displaying a prominent notice on the Service

Your continued use of the Service after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. If you do not agree to the updated Privacy Policy, you must stop using the Service and may delete your Account.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

16. Data Protection Officer

We have designated a Data Protection Officer (DPO) responsible for overseeing our data protection practices and ensuring compliance with Indonesian data protection law. If you have questions or concerns about how we handle your personal data, you may contact our DPO at:

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:

We will respond to your inquiry within a reasonable timeframe, typically within 30 days, as required by Indonesian data protection law.

18. Consent and Acknowledgment

By using the Service, you acknowledge that you have read, understood, and agree to this Privacy Policy. You consent to the collection, use, and disclosure of your personal data as described in this Privacy Policy.

If you do not agree with this Privacy Policy, you must not access or use the Service.

20. Sensitive Personal Data

We generally do not collect or process sensitive personal data (such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health data, biometric data, or sexual orientation) unless:

• You explicitly provide such data voluntarily
• We have obtained your explicit consent for specific purposes
• Processing is required by Indonesian law
• Processing is necessary for legal claims or official authority functions

If you choose to include sensitive personal data in your Content (such as in property descriptions or client notes), you are responsible for obtaining any necessary consents from the data subjects and ensuring compliance with applicable laws.

21. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify the relevant Indonesian data protection authorities within 72 hours of becoming aware of the breach, as required by law
• Notify affected users without undue delay if the breach is likely to result in a high risk to their rights and freedoms
• Provide clear information about the nature of the breach, the categories and approximate number of data subjects affected, and the likely consequences
• Describe the measures taken or proposed to address the breach and mitigate its possible adverse effects
• Provide contact details for further information and assistance

We maintain comprehensive incident response procedures to detect, investigate, and respond to data breaches promptly and effectively.

22. Privacy by Design and Default

We implement privacy by design and by default principles in the development and operation of the Service. This means:

• Data Minimization: We collect only the personal data that is necessary for the specified purposes
• Purpose Limitation: We process personal data only for the purposes for which it was collected
• Storage Limitation: We retain personal data only for as long as necessary
• Security by Default: Default settings are configured to maximize privacy and security
• Transparency: We provide clear information about our data processing practices
• User Control: We give you control over your personal data and privacy settings

23. Cross-Border Collaboration Features

If you use our collaboration features to share property listings or data with team members or clients who are located in different countries, please be aware that:

• The data you share will be accessible to the recipients in their respective locations
• You are responsible for ensuring you have the right to share such data and for complying with applicable cross-border data transfer requirements
• We provide tools to help you control who can access your shared data
• Recipients may be subject to different privacy laws in their jurisdictions

24. Mobile Application Permissions

When you use our mobile application, we may request access to certain device features and data. We will only request permissions that are necessary for the functionality of the app:

• Camera: To take photos of properties for listings (only when you use this feature)
• Photo Library: To upload existing photos to property listings
• Location: To tag properties with location data and show nearby properties (only with your permission)
• Notifications: To send you important updates and alerts (you can disable these in device settings)
• Storage: To save documents, photos, and other files locally on your device
• Internet/Network: To sync your data and access cloud features

You can manage these permissions through your device settings at any time. Denying certain permissions may limit some functionality of the app.

25. California Privacy Rights (If Applicable)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). However, as our company is based in Indonesia and primarily serves Indonesian users, these laws may not apply to our processing of your data. If you believe you have rights under California law, please contact us at hello@prodaidn.com for more information.

26. GDPR Rights (For European Users)

If you are located in the European Economic Area (EEA) or United Kingdom, you may have additional rights under the General Data Protection Regulation (GDPR). While we primarily serve Indonesian users, if GDPR applies to you, you may have additional rights including more extensive data portability rights and the right to object to certain processing activities. Please contact us at hello@prodaidn.com if you believe GDPR applies to your situation.

27. Business Transactions and Your Data

If PT. Solusi Proda Indonesia is involved in a merger, acquisition, asset sale, bankruptcy, or other business transaction, your personal data may be among the assets transferred. In such cases:

• We will notify you via email and/or prominent notice on our Service before your data is transferred
• The acquiring entity will be required to honor this Privacy Policy
• You will have the opportunity to delete your Account and data before the transfer if you do not wish your data to be transferred
• If the acquiring entity intends to materially change how your data is handled, they must obtain your consent or allow you to opt out

28. Research and Development

We may use aggregated, anonymized, or pseudonymized data for research and development purposes to:

• Improve our algorithms and machine learning models
• Develop new features and services
• Conduct market research and trend analysis
• Generate industry insights and reports

This data cannot be used to identify you individually. If we wish to use your personal data for research purposes beyond what is described in this Privacy Policy, we will obtain your explicit consent.

29. Government and Regulatory Compliance

As a company operating in Indonesia's real estate industry, we may be subject to various regulatory requirements. We may share your information with Indonesian government agencies and regulatory bodies when:

• Required by Indonesian law or regulation
• Necessary to comply with tax, financial reporting, or anti-money laundering requirements
• Requested by authorized government agencies with proper legal authority
• Necessary to comply with real estate industry regulations

We will only disclose the minimum amount of information necessary to comply with such requirements.

30. Updates and Communication Preferences

You can control the communications you receive from us:

30.1 Email Preferences

• Marketing Emails: You can opt out at any time using the unsubscribe link or by updating your preferences
• Transactional Emails: These are essential for the Service and cannot be disabled (e.g., password resets, payment receipts)
• Product Updates: You can choose whether to receive updates about new features and improvements

30.2 Push Notifications

If you use our mobile app, you can control push notifications through your device settings or in-app preferences. You can enable or disable notifications for different types of activities.

30.3 SMS Communications

We may send SMS messages for account security purposes (e.g., two-factor authentication) or important service updates. You can opt out of promotional SMS by replying STOP, but security-related messages cannot be disabled while your Account is active.

31. Accountability and Oversight

We maintain accountability for all personal data processing activities:

• We maintain records of all processing activities as required by Indonesian data protection law
• We conduct regular privacy impact assessments for new features and services
• We provide regular training to staff on data protection and privacy practices
• We monitor compliance with this Privacy Policy and applicable laws
• We conduct periodic audits of our data protection practices
• We maintain documentation demonstrating our compliance with data protection obligations

32. Your Responsibilities

As a user of the Service, you also have responsibilities regarding data protection:

• Accuracy: Ensure the information you provide is accurate and up to date
• Security: Protect your Account credentials and notify us of any unauthorized access
• Third-Party Data: If you upload data about clients, prospects, or third parties, ensure you have the legal right to do so and have obtained necessary consents
• Compliance: Use the Service in compliance with applicable laws and regulations
• Team Access: If you grant access to team members, ensure they understand and comply with applicable data protection requirements
• Data Subject Rights: If your clients request to exercise their rights regarding data you've stored in our Service, you are responsible for responding to those requests

33. Interpretation and Definitions

For the purposes of this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, and deletion
• "Controller" means the entity that determines the purposes and means of processing personal data
• "Processor" means an entity that processes personal data on behalf of the controller
• "Data Subject" means the individual to whom personal data relates
• "Consent" means freely given, specific, informed, and unambiguous indication of agreement to processing of personal data

34. Questions and Feedback

We welcome your questions, comments, and feedback about this Privacy Policy and our data protection practices. Your input helps us improve our privacy practices and better serve you.

Please don't hesitate to contact us if you:

• Have questions about how we handle your personal data
• Want to exercise any of your data protection rights
• Have concerns about our privacy practices
• Want to report a potential privacy or security issue
• Need clarification on any part of this Privacy Policy
• Have suggestions for improving our privacy practices

We are committed to addressing your concerns promptly and transparently.