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PRIVACY POLICY

Last Updated: October 12, 2025

This Privacy Policy (“Policy”) explains how PT Cakrawala Kreatif Digital (“Company,” “we,” “our,” or “us”) collects, uses, stores, discloses, and protects personal data in connection with your use of our platform, software, websites, and related services (collectively referred to as the “Services”).

By accessing or using our Services, you acknowledge that you have read and understood this Policy and agree to our collection and use of your data as described herein. If you do not agree, please discontinue use of the Services.

1. Scope of this Policy

This Policy applies to all Business Users, their customers, and any individuals whose personal data is collected, processed, or stored through the Services provided by PT Cakrawala Kreatif Digital via bayarin.id.

This Policy is designed to comply with:

• Law No. 27 of 2022 on Personal Data Protection (UU PDP); and
• relevant international standards for data protection and privacy.

2. Definitions

For purposes of this Policy:

• “Personal Data” means any data about an identified or identifiable individual, whether directly or indirectly.
• “Customer Data” means any data uploaded, submitted, or processed through the Services by a Business User, including personal data belonging to their end customers.
• “Processing” means any activity involving Personal Data, including collection, storage, analysis, transfer, or deletion.
• “Business User” refers to companies or individuals using our Services to manage their business operations.
• “End User” refers to a customer, client, or individual interacting with a Business User through our Services.

3. Personal Data We Collect

We may collect the following categories of Personal Data, depending on how you use our Services:

a. Data Provided Directly by Business Users

• Company name, contact details, and business registration information;
• Name, email address, and phone number of account administrators or users;
• Billing and payment details;
• Customer interaction data uploaded to the platform.

b. Data Automatically Collected

• Log data such as IP address, browser type, operating system, access times, and pages viewed;
• Device identifiers and session information;
• Usage analytics, performance metrics, and interaction logs between Business Users and AI agents.

c. Data from Third Parties

We may receive information from third-party service providers, such as:

• CRM platforms, communication tools, or integrated APIs;
• Payment gateways and cloud infrastructure partners.

4. How We Use Personal Data

We process Personal Data for the following purposes:

1. To Provide and Operate the Services
   • Enable account creation, authentication, and user management.
   • Deliver customer service and AI-assisted communication features.
2. To Improve and Develop the Services
   • Analyze usage data to enhance platform performance.
   • Train and refine AI models using anonymized or aggregated data.
   • Conduct research and testing for system optimization.
3. To Ensure Security and Compliance
   • Monitor for fraud, abuse, or unauthorized access.
   • Comply with applicable legal obligations.
4. To Communicate with You
   • Send service updates, technical notices, billing information, and support messages.
   • Provide marketing or promotional materials (with your consent).

5. Legal Basis for Processing

We process Personal Data based on one or more of the following legal grounds:

• Your consent;
• Performance of a contract or provision of Services;
• Compliance with legal obligations;
• Legitimate interests pursued by the Company (e.g., improving the Services or preventing misuse).

6. Data Retention

We retain Personal Data only for as long as necessary to fulfill the purposes outlined in this Policy, or as required by law. Upon termination of a Business User’s account, data may be deleted or returned upon written request, subject to our retention policy and backup cycles.

7. Data Sharing and Disclosure

We do not sell or rent Personal Data. We may share data only under the following circumstances:

• With Authorized Third-Party Service Providers: For cloud hosting, AI processing, payment, analytics, or support purposes.
• With Legal or Regulatory Authorities: When required by law, court order, or lawful government request.
• In the Event of a Business Transaction: In case of a merger, acquisition, or restructuring, provided that the receiving entity agrees to protect the data in accordance with this Policy.

All third-party partners are bound by contractual obligations to maintain confidentiality and data protection standards consistent with applicable laws.

8. International Data Transfers

If data is transferred or processed outside Indonesia, we ensure that adequate data protection measures are in place, consistent with the UU PDP and other applicable regulations. This may include standard contractual clauses, encryption, or anonymization.

9. Data Subject Rights

Under Law No. 27 of 2022, you have the following rights regarding your Personal Data:

1. Right to Information – to be informed about how your data is processed;
2. Right to Access – to request a copy of your personal data;
3. Right to Rectification – to correct inaccurate or incomplete data;
4. Right to Erasure – to request deletion of data under certain conditions;
5. Right to Withdraw Consent – to revoke your consent at any time;
6. Right to Object or Restrict Processing – to limit certain uses of data;
7. Right to Data Portability – to obtain your data in a structured, machine-readable format.

Requests may be submitted via legal@bayarin.id, and we will respond in accordance with applicable legal timeframes.

10. Security of Personal Data

We implement technical and organizational measures to protect Personal Data against unauthorized access, loss, or alteration, including:

• Data encryption in transit and at rest;
• Secure authentication mechanisms;
• Access controls and staff confidentiality agreements;
• Regular security audits and monitoring.

However, no electronic system is entirely secure, and we cannot guarantee absolute security.

11. AI Data Processing and Model Training

Customer Data may be used to train or improve AI systems in anonymized or aggregated form. We take steps to ensure that:

• Identifiable personal data is not disclosed in model outputs;
• Training datasets are securely handled and access-controlled;
• Business Users may opt out of future data training by contacting legal@bayarin.id.

12. Cookies and Tracking Technologies

We may use cookies, web beacons, or similar technologies to enhance user experience and collect analytics. You can manage or disable cookies through your browser settings, though some features may not function properly without them.

13. Children’s Privacy

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect Personal Data from minors. If we learn that data from a minor has been collected, we will promptly delete it.

14. Changes to this Policy

We may update this Privacy Policy periodically. The most recent version will always be available on our website, and continued use of the Services constitutes acceptance of any changes.

15. Contact Us

For questions, concerns, or data protection requests, please contact:

📧 Support: hello@bayarin.id
📧 Legal / Data Protection Officer: legal@bayarin.id

🏢 PT Cakrawala Kreatif Digital
Rumah Susun Komersial Campuran GP Plaza
Jl. Gelora II, LD Floor, Unit LD-0
Central Jakarta, DKI Jakarta, Indonesia