1. Personal Data We Collect

Depending on how you interact with CBC, we may collect the following information:

A. Information You Provide Directly

This may include:

• Full name
• Company name
• Job title or position
• Email address
• Telephone or WhatsApp number
• Business address
• Country of residence or nationality
• Information regarding your business
• Business needs or consultation requirements
• Information submitted through contact forms or consultation booking forms
• Any other information you voluntarily provide to us

B. Information Collected Automatically

When you visit our website, certain information may be collected automatically, including:

• IP address
• Browser type and version
• Device information
• Operating system
• Pages visited
• Date and time of access
• Referring website
• Website interaction and usage data

This information may be collected through cookies, analytics tools, or similar technologies.

2. How We Use Your Personal Data

CBC may process your Personal Data for the following purposes:

• Responding to your inquiries and requests
• Providing business consulting and professional services
• Scheduling and managing consultations
• Preparing proposals, agreements, or other business documents
• Communicating with you regarding our services
• Managing our client and prospect relationships
• Improving our website, services, and customer experience
• Understanding website usage and improving our marketing activities
• Sending relevant business updates, information, or marketing communications where permitted
• Complying with applicable laws and regulatory requirements
• Protecting our legal rights, systems, and business operations

We will only process Personal Data for purposes that are relevant and appropriate to the context in which the information was collected and in accordance with applicable laws.

3. Legal Basis for Processing

Depending on the circumstances, CBC may process Personal Data based on one or more lawful grounds, including:

• Your consent;
• The performance of a contract or steps taken at your request prior to entering into a contract;
• Compliance with applicable legal or regulatory obligations;
• Protection of legitimate interests, where permitted by applicable law; or
• Other lawful grounds recognized under applicable laws and regulations.

Under Indonesia’s Personal Data Protection Law, processing of Personal Data is subject to applicable principles and requirements concerning lawful processing and protection of Personal Data.

4. Consultation and Contact Forms

If you submit an inquiry, contact form, consultation request, or booking request through our website, CBC may use the information you provide to:

• Contact you regarding your inquiry;
• Understand your business requirements;
• Arrange a consultation;
• Assign your inquiry to the appropriate CBC team member;
• Prepare relevant information or proposals; and
• Follow up regarding our services.

Where a third-party platform is used to facilitate forms, scheduling, communication, or other services, your Personal Data may also be processed by that third party in accordance with its applicable privacy policy.

5. Cookies and Similar Technologies

Our website may use cookies and similar technologies to:

• Ensure the website functions properly;
• Remember certain preferences;
• Understand how visitors use our website;
• Measure website performance;
• Improve user experience; and
• Support marketing and advertising activities, where applicable.

You may configure your browser to refuse or limit cookies. However, certain website functions may not operate properly if cookies are disabled.

6. Third-Party Services

CBC may use third-party service providers to support our business operations and website, including services relating to:

• Website hosting;
• Google Analytics & META Pixel;
• Email communication;
• Calendar and consultation scheduling;
• Online forms;
• Customer relationship management;
• Marketing and advertising;
• Cloud storage; and
• Other business administration services.

These third parties may process Personal Data on our behalf or independently depending on the nature of their services.

CBC takes reasonable steps to work with service providers that maintain appropriate safeguards for Personal Data.

7. Google Services and Online Consultation

Where applicable, CBC may use Google services such as Google Calendar, Google Meet, Google Forms, Google Sheets, or other Google Workspace services to manage consultations, appointments, communications, or business operations.

Information required to schedule a consultation may be shared with the relevant Google service to facilitate the requested service.

Google’s processing of information is also subject to Google’s applicable privacy policies and terms.

8. Disclosure of Personal Data

CBC does not sell your Personal Data.

We may disclose or provide access to Personal Data where reasonably necessary to:

• CBC employees, consultants, or authorized personnel;
• Professional advisers and service providers;
• Technology, hosting, communication, or software providers;
• Government authorities or regulatory bodies where required by law;
• Parties involved in legal proceedings or the protection of legal rights; or
• Other parties with your consent or where otherwise permitted by applicable law.

We will seek to limit disclosure to information that is reasonably necessary for the relevant purpose.

9. International Data Transfers

Some of our service providers or technology platforms may process or store Personal Data outside Indonesia.

Where Personal Data is transferred outside Indonesia, CBC will take reasonable steps to ensure that such transfer is conducted in accordance with applicable laws and that appropriate safeguards are implemented.

10. Data Retention

CBC retains Personal Data only for as long as reasonably necessary to:

• Fulfill the purposes for which the information was collected;
• Provide our services;
• Maintain business and client records;
• Fulfill contractual or legal obligations;
• Resolve disputes; or
• Protect our legitimate business interests.

When Personal Data is no longer required, CBC may delete, anonymize, or securely dispose of it in accordance with applicable laws and our internal procedures.

11. Data Security

CBC takes reasonable technical and organizational measures to protect Personal Data against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

However, no method of electronic transmission or storage can be guaranteed to be completely secure.

In the event of a Personal Data security incident requiring notification under applicable law, CBC will take the necessary steps in accordance with applicable legal requirements.

12. Your Rights

Subject to applicable laws and regulations, you may have certain rights regarding your Personal Data, including the right to:

• Obtain information regarding the processing of your Personal Data;
• Access your Personal Data;
• Correct or update inaccurate or incomplete Personal Data;
• Request deletion or destruction of Personal Data in certain circumstances;
• Withdraw consent where processing is based on consent;
• Object to or request restriction of certain processing activities where applicable;
• Request transfer of your Personal Data where applicable; and
• Submit a complaint regarding the processing of your Personal Data.

Indonesia’s UU PDP expressly regulates rights of Personal Data Subjects, including rights relating to access, correction, deletion, withdrawal of consent, and other protections.

Requests relating to your Personal Data may be submitted using the contact details provided below.

13. Children’s Privacy

Our website and services are not intentionally directed toward children.

CBC does not knowingly collect Personal Data from children without appropriate authorization or legal basis.

If you believe that a child has provided Personal Data to CBC without appropriate consent, please contact us so that we can take appropriate action.

14. Changes to This Privacy Policy

CBC may update this Privacy Policy from time to time to reflect changes in our services, technology, business practices, or applicable laws and regulations.

Any updated version will be published on this page with the relevant Last Updated date.

We encourage you to review this Privacy Policy periodically.