Privacy & Cookie Policy

Introduction

PT Central Sudirman Development ("our", "us" or "we") are committed to protecting your privacy and safeguarding your personal data in our possession. This Privacy Policy ("Policy") transparently explains how, when, and why we use your personal data, as well as your rights regarding the usage of such personal data when you visit our website (duatwosudirman.com) and/or when you interact with us.

We only collect and use your personal data as outlined below. This Policy is only intended for our customers and tenants. By using our services and/or interacting with us, you acknowledge that any personal data you provide to us is true, complete, lawfully obtained, and that you are fully entitled to provide such personal data to us.

The Personal Data We Collect

The types of personal data we collect from you will depend on the specific type of services and products as requested by, or provided to, you. The types of personal data may include (without limitation) the following:

• Your personal information (e.g. your name, gender, date of birth, passport or other personal identification card number)
• Your contact information (e.g. telephone numbers, mailing addresses, email addresses, postal code and fax numbers)
• Your business information (e.g. company name, business title and associated contact information)

Certain Personal Data are required for specific services and if you fail to supply such Personal Data as requested, we may not be able to deliver to you the services or products.

Purposes of Your Personal Data

The purposes for which your Personal Data are collected and used may include (without limitation):

• For the supply of any services, products, facilities and/or other subjects which we or any of our subsidiaries may offer to you
• For use of the online services available at any of the websites of TSJ and/or through other telecommunication channels
• With your consent, for marketing or promoting any of the Services of TSJ
• For identification and verification purposes in connection with any of the Services supplied to you
• For reservations with or through us, and for communicating with you by email, mail, fax, phone or other means
• For managing customer or tenant relationships
• For making disclosures when required by law, regulation, or court order
• For establishing legal claims or defenses, obtaining legal advice, and/or exercising rights

We will not knowingly or intentionally use, share or sell your Personal Data in ways which are unrelated to the above purposes without your prior consent.

Disclosure & Transfer of Personal Data

To facilitate the purposes mentioned above, we may transfer, disclose, or share your Personal Data with third parties located within or outside Indonesia. These third parties may include:

• Agents, contractors or third-party service providers who provide administrative, marketing, research, data processing or other services
• Other business associates such as loyalty programme operators
• Credit reference agencies, credit, debit and/or charge card companies and/or banks
• Medical professionals, clinics, hospitals, insurers and/or loss adjustors
• Any person, government or law enforcement authority
• Any person under a duty of confidentiality to any member of TSJ
• Any actual or proposed assignee or purchaser of all or any part of our business
• Charitable or non-profit making organizations

Our Commitment to Children's Privacy

Protecting the privacy of children is our primary concern. Generally, we will not knowingly collect or maintain Personal Data from persons who are under 17 years of age without prior consent from a parent or guardian.

In Indonesia specifically, we will not knowingly collect Personal Data from persons under 14 years of age without prior parental consent, and will only collect data from persons between 14 and 18 years of age if explicit consent has been obtained from such person or their parent or guardian.

Your Rights as a Data Subject

You have certain rights as a data subject:

• The right to be informed about the Company's identity, purposes of data processing, and the lawful basis for such processing
• The right to request and obtain access to your personal data that we hold at any time
• The right to complete, update, and correct any errors or inaccuracies in your personal data
• The right to request the cessation of processing, deletion, or destruction of your personal data
• The right to withdraw your consent for the processing of your personal data at any time
• The right to object to decisions made solely based on automated processing
• The right to request a delay or limitation in the processing of your personal data
• The right to request that your personal data be moved or transferred from our system to another system

Please note that exercising certain rights (such as withdrawal of consent) may affect access to and/or limit the Company's services that you can use.

Use of Cookies & Log Files

If you visit our website, we may use cookie files to store and track information about you and your preferences. A cookie is a small text file that our website transfers to your computer's or device's hard disk. We use cookies to better serve you and/or maintain your information across multiple pages within or across one or more sessions.

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future. However, if you disable cookies or refuse to accept a request to place a cookie, certain functionalities on our website may not be available.

We also use Google Analytics (GA4) to understand how visitors interact with our website. Google Analytics uses cookies to collect information such as how often users visit this site, what pages they visit, and what other sites they used prior to coming to this site. We use this information only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information.

We may also collect information regarding your IP address, browser type, domain name and access time for research purposes. In rare instances, IP addresses may be used to assist in deterring and/or preventing abusive or criminal activity on the website.

Data Retention

Subject to any legal, statutory, regulatory or accounting requirements, the Personal Data you provide to us will be kept by us in the appropriate form only for as long as is necessary to fulfill the purposes mentioned above, after which it will be destroyed.

Data Security

In order to ensure the correct use and to maintain the accuracy of the Personal Data collected from you, as well as preventing unauthorized or accidental access, processing, erasure or other use of the Personal Data, we have implemented various internal policies (including physical, electronic and management measures) to safeguard and secure the Personal Data we collect.

We endeavour to improve our standards of protection; however, you acknowledge that we are not liable for any losses arising from the destruction or loss of your Personal Data that occurs beyond our control and the transmission of information via the internet is not completely secure.

Third-Party Sites & Applications

Our services or communications with you may from time to time contain links to third-party websites, applications, plug-ins or services over which we have no control. We will not share your Personal Data with these third-party companies; only you can do so if you choose.

Links to third-party websites provided on our website are offered for your convenience. However, we do not control those websites or their personal data protection practices. We recommend you read such third-party personal data protection notices to understand your rights.

Communications & Marketing

We may use your Personal Data (including your name and contact details) to send you communications by email, post, telephone, text message, or other digital methods for the purposes of:

• Fulfilling our legal obligations (for example, notifying you of changes to our agreement)
• Informing you about the features and benefits of the products and services we provide
• Informing you about products and services that may be of interest to you

You may request to stop or start receiving marketing communications at any time by contacting us using the details set out below.

Governing Law & Dispute Resolution

This Policy is regulated and interpreted according to the laws and regulations of the Republic of Indonesia.

Any dispute shall be resolved by the relevant parties amicably and by deliberation to reach consensus within 30 (thirty) calendar days of a party receiving a written notice of such dispute from the other party. If the dispute cannot be resolved within 30 calendar days, it will be referred to and finally resolved in BANI, with the seat of arbitration in Jakarta, Indonesia.

Contact Us

If you have any questions or concerns regarding this Policy or your personal data, please contact us at: