Privacy and Personal Data Protection Policy
PT SULUBAN BEACH DEVELOPMENT
Website: https://surfsidebali.com
1. Introduction
This Privacy and Personal Data Protection Policy (“Policy”) is issued by PT SULUBAN BEACH DEVELOPMENT (“Operator”, “we”, or “us”) in accordance with Law No. 27 of 2022 on Personal Data Protection of the Republic of Indonesia (“PDP Law”). This Policy explains how we collect, use, store, process, and protect personal data of users of our website and services (“Users” or “Data Subjects”).
We are committed to protecting your personal data and ensuring that your privacy is respected and protected in accordance with applicable laws.
2. Definitions
  • Personal Data: Any data about an individual who is identified or can be identified either directly or indirectly through such data.
  • Data Subject: A natural person whose personal data is processed.
  • Processing: Any action or set of actions relating to personal data, including collection, recording, storage, alteration, use, disclosure, transmission, deletion, or destruction.
  • Consent: A voluntary, explicit, and informed agreement by the Data Subject to allow the processing of their personal data.
  • Third Party: Any person or entity other than the Operator and the Data Subject.
3. Legal Basis for Processing
We process your personal data based on one or more of the following legal grounds:
  • Your explicit consent
  • The performance of a contract with you
  • Compliance with legal obligations
  • Legitimate interests of the Operator that do not override your rights and freedoms
4. Types of Personal Data We Collect
We may collect the following categories of personal data:
  • Full name
  • Email address
  • Phone number
  • Communication preferences
  • Reservation and booking details
  • Website usage data (via cookies and analytics)
5. Purposes of Data Processing
We process your personal data for the following purposes:
  • To respond to inquiries and provide customer support
  • To manage reservations, contracts, and guest records
  • To send administrative and promotional communications
  • To improve the performance and security of our website
  • To comply with legal and regulatory obligations
6. Consent and Withdrawal
By using our website or providing us your personal data, you consent to the collection, use, and disclosure of your personal data in accordance with this Policy.
You may withdraw your consent at any time by sending an email to: surfsideprojectbali@gmail.com with the subject “Withdrawal of Consent”.
7. Data Sharing and Disclosure
We do not sell or rent your personal data. We may disclose your personal data to third parties only in the following cases:
  • With your prior consent
  • To comply with legal obligations or court orders
  • To service providers who process data on our behalf under appropriate confidentiality and security obligations (e.g., hosting providers, marketing services)
  • In case of a business transaction (e.g., merger or acquisition), with appropriate safeguards
8. International Data Transfers
If your data is transferred to a country outside Indonesia, we will ensure that:
  • The recipient country has adequate data protection standards, or
  • We obtain your explicit consent, or
  • Other appropriate legal mechanisms are in place (e.g., data transfer agreements)
9. Data Retention
We retain personal data for as long as necessary to fulfill the purposes stated in this Policy or as required by applicable laws. Once the data is no longer needed, we will securely delete or anonymize it.
10. Rights of Data Subjects
As a Data Subject, you have the following rights under the PDP Law:
  • Right to obtain information about data processing
  • Right to access your personal data
  • Right to correct or update your data
  • Right to withdraw consent
  • Right to object to processing
  • Right to restrict or suspend processing
  • Right to erasure (“right to be forgotten”)
  • Right to data portability
  • Right to file a complaint with the relevant authority (Ministry of Communication and Information Technology)
To exercise any of these rights, please contact us at surfsideprojectbali@gmail.com.
11. Data Security
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, use, alteration, disclosure, or destruction. These measures include but are not limited to:
  • Data encryption
  • Access control mechanisms
  • Secure data storage and backups
12. Cookies and Tracking Technologies
We may use cookies and similar technologies to enhance user experience, analyze website performance, and deliver relevant advertisements. You can manage or disable cookies in your browser settings.
13. Third-Party Services
Our website may include links to third-party websites and services. We are not responsible for the privacy practices of such third parties. We encourage you to review their privacy policies.
14. Changes to This Policy
This Policy may be updated from time to time. Any changes will be posted on our website at: https://surfsidebali.com/policy
We recommend reviewing this Policy periodically to stay informed of any updates.
15. Contact InformationIf you have any questions or requests regarding this Privacy Policy or the processing of your personal data, please contact us at:
📧 surfsideprojectbali@gmail.com