1. Who we are
The personal data controller is PT PREMIER DEVELOPMENT GROUP, registered under the laws of the Republic of Indonesia (hereinafter referred to as the “Company,” “we,” or “us”).
The website is owned by PT PREMIER DEVELOPMENT GROUP, the developer of ELISON HOTEL in the Berawa area of Canggu, Bali. We act as the controller of your personal data. Company details are provided at the top of this page.
The Company determines the purposes and means of processing personal data obtained through the ELISON HOTEL website and associated communication channels.
2. What data we may collect
Data you provide to us directly:
- name, phone number, WhatsApp account, and email address;
- the content of your messages and inquiries, including your preferred scenario (immediate investment or installment purchase);
- any other information you choose to share with us during communication.
Data collected automatically when using the website:
- technical data: IP address, browser and device type, operating system, language, pages viewed, and visit duration;
- information on how you found us: advertising parameters (UTM tags, gclid, fbclid) and the referring page. They are stored in your browser for up to 30 days and added to the WhatsApp message as a short code so that we can understand which advertising campaign led you to us;
- cookies and similar technologies — see Section 5.
We do not intentionally collect special categories of personal data. The website is not intended for persons under the age of 18.
By providing the Company with the personal data of third parties, the user confirms that they have the legal grounds to transfer such data to the Company and, where required by applicable law, have obtained the necessary consents from such persons. The user is responsible for the accuracy and lawfulness of providing such data to the extent established by applicable law.
3. Why we use data
- To respond to your inquiry and provide information about ELISON HOTEL, available apartments, prices, and payment terms — actions taken at your request prior to concluding a contract and our legitimate interest in responding to inquiries.
- To communicate with you and store the history of inquiries in the CRM system — our legitimate interest in organizing sales.
- To analyze website usage and improve the site — your consent (analytical cookies).
- To evaluate advertising effectiveness and show you relevant ads — your consent (marketing cookies).
- To comply with legal requirements and protect our rights — legal obligation and legitimate interest.
If processing is based on your consent, you may withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.
If you have independently sent us an inquiry, provided contact details, or initiated communication with the Company, we reserve the right to use the provided contact details to respond to your inquiry and for subsequent communication regarding the subject of your inquiry, including clarifying your interest in the property, purchase terms, and available payment options.
4. Basis for data processing
Depending on the specific situation, personal data processing is carried out based on:
- your consent;
- the need to take action at your request prior to entering into a contract;
- the need to enter into or perform a contract;
- compliance with obligations established by applicable law;
- the Company’s legitimate interests, provided such interests do not infringe upon your rights and freedoms.
If processing is based on your consent, you have the right to withdraw it at any time. Withdrawing consent does not affect the lawfulness of processing carried out prior to the withdrawal.
6. Who data may be shared with
We do not sell your personal data. We share it only with parties that help us operate the site and process your inquiries. We may engage third-party service providers to ensure the site functions correctly and to facilitate user interaction.
Depending on the features used, personal data may be processed by providers of hosting, CRM systems, communication services, and analytics or advertising tools, among others.
Such services may include Vercel, WhatsApp/Meta, Wazzup, Kommo, Google Analytics, Google Ads, and Meta Pixel, provided these services are utilized on the site or during interactions with you. Such recipients process data to the extent necessary to provide the relevant services and in accordance with applicable legal requirements and contractual obligations.
Some of the services we use may process or store data outside Indonesia or your country of residence.
When transferring personal data outside the Republic of Indonesia, the Company employs safeguards for cross-border data transfers as prescribed by applicable law. Depending on the circumstances, such measures may include assessing the level of personal data protection in the recipient country, implementing contractual or other mandatory safeguards, or obtaining the data subject’s consent where required by law.
Personal data may also be disclosed to the Company’s professional advisors (including legal, tax, accounting, and other consultants), auditors, insurance companies, banks and payment service providers, government authorities, and other parties, where such disclosure is necessary for contract performance, compliance with legal requirements, or the establishment, exercise, or defense of the Company’s legal rights and interests.
In the event of a corporate reorganization, sale of the business or a part thereof, investment, project transfer, merger, acquisition, or other corporate transaction, personal data may be disclosed to potential or actual parties to the transaction and their professional advisors to the extent necessary to evaluate and execute the transaction, subject to compliance with applicable personal data protection requirements.
7. How long we retain data
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected.
The specific retention period depends on the nature of the data, the purpose of processing, the duration of the relationship with the user, legal requirements, and the need to protect the Company’s legitimate interests.
Once the need for data retention ceases, the data is deleted, anonymized, or otherwise removed from active processing, unless further retention is required by law. Even after the original purpose of processing has ceased, certain data may be retained for the period necessary to comply with legal, accounting, and tax requirements; to handle claims and resolve disputes; to prevent fraud; and to establish, exercise, or defend the Company’s rights and legitimate interests.
8. How we protect data
We implement reasonable organizational and technical measures to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction.
However, no method of data transmission or storage over the Internet can guarantee absolute data security. Users are also responsible for taking reasonable security precautions when using their own devices, accounts, and communication channels. The Company bears no liability for any breach of confidentiality arising from circumstances beyond its reasonable control, to the extent permitted by applicable law.
9. Your rights
Depending on applicable law, you may have the right to:
- obtain information regarding the processing of your personal data;
- request access to your data;
- request the correction of inaccurate or incomplete data;
- request the deletion of data in cases provided for by law;
- restrict data processing;
- object to certain processing methods;
- withdraw previously given consent;
- receive your data in a portable format, if such right is provided for by law;
- lodge a complaint with a competent data protection authority.
To exercise your rights, you may contact us at: info@pgd.estate.
Before fulfilling a request, we may ask for information necessary to verify the requester’s identity and prevent unauthorized access to data.
These rights are not absolute and are exercised subject to the conditions and limitations set forth in applicable law. In particular, the Company may be entitled to continue storing or processing certain data if necessary to comply with a legal obligation, perform or substantiate contractual relationships, resolve a dispute, or establish, exercise, or defend legal claims.
10. Data of minors
The website and our services are not intended for the intentional collection of personal data of minors.
If we become aware that the personal data of a minor has been obtained without the necessary consent of a parent or other legal guardian, we will take reasonable measures in accordance with applicable law.
11. Links and third-party services
The website may contain links to third-party websites and services.
When visiting such a website or using a third-party service, you may be subject to its own privacy policy. The Company does not determine the data processing methods of independent third-party operators and recommends reviewing their privacy policies. The Company is not responsible for the content, security, or personal data processing practices of third-party websites and services acting as independent data controllers, except to the extent that applicable law imposes such liability on the Company. The inclusion of a link to a third-party resource does not imply the Company’s endorsement of its privacy policy or data processing practices.
12. Policy updates
We may update this Policy periodically, particularly in response to changes in legislation, technologies used, or personal data processing procedures.
The current version is always published on this page. If changes significantly affect personal data processing procedures, we may additionally notify users in a manner appropriate to the nature of our relationship with them. Unless otherwise provided by applicable law, the updated Policy takes effect upon its publication on the website.
13. Applicable law
Personal data processing is conducted in accordance with the applicable personal data protection laws of the Republic of Indonesia, including Law of the Republic of Indonesia No. 27 of 2022 on Personal Data Protection.
Where the laws of other jurisdictions — including the General Data Protection Regulation (EU) 2016/679 (GDPR) — apply to specific personal data processing activities, the Company complies with such requirements to the extent applicable.
14. How to contact us
If you have questions regarding this Policy or the processing of your personal data, please email us at info@pgd.estate or send a letter to the office address listed at the top of this page.