Legal Document

Privacy Policy

Last updated: 18 April 2026 · Version 1.2

This English translation is provided for convenience only. The Indonesian version is the legally binding version and prevails in the event of any discrepancy.

1. Introduction

PT PAWSI Digital Indonesia (“PAWSI”, “we”, “us”) is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use PAWSI's services, in accordance with Law No. 27 of 2022 on Personal Data Protection (“UU PDP”) and related laws and regulations in Indonesia.

By using our services, you consent to the collection and use of information in accordance with this policy. If you do not agree with this policy, please do not use our services.

2. Information We Collect

2.1 Information You Provide

We collect information you provide directly to us when you:

  • Register an account: full name, email, phone number, business name, and business address.
  • Complete a business profile: business type, operating hours, and tax information (NPWP).
  • Make a payment: payment information is processed through a secure payment gateway; we do not store your credit card details.
  • Contact customer support: communications with our support team via email or WhatsApp.

2.2 Your Business's Customer Data

When you use PAWSI to manage your pet care business, you enter data about your business's customers:

  • Customer information: name, phone number, email, and address.
  • Pet information: name, species, breed, age, health condition, allergies, and preferences.
  • Transaction and service history.
  • Medical and grooming records.

Important: you are fully responsible for the customer data you enter into the system. You must ensure that you have a lawful basis—including consent—from your customers to collect and process their data.

2.3 Automatically Collected Information

When you use our services, we automatically collect:

  • Technical information: IP address, browser type, operating system, and device type.
  • Usage data: pages visited, features used, access times, and frequency of use.
  • Activity logs: actions taken within the system, for security and audit purposes.
  • Cookies and similar technologies: to improve the user experience and for analytics.

2.4 Categories of Personal Data

Pursuant to Article 4 of the UU PDP, the data we process includes the category of General Personal Data (e.g. name, email, phone number, address, business identity data) and, in certain cases, may include Specific Personal Data (e.g. personal financial data related to transactions, animal health data linked to an owner). Specific personal data is processed with extra care and only for lawful purposes.

2.5 Legal Basis for Processing

Pursuant to Article 20 of the UU PDP, PAWSI's processing of personal data is based on one or more of the following legal bases:

  • Valid consent: when you give explicit consent (e.g. account registration, subscribing to marketing communications).
  • Performance of a contract: to provide the Services in accordance with PAWSI's Terms and Conditions.
  • Legal obligation: to fulfil tax, accounting, and other statutory and regulatory obligations.
  • Legitimate interest: for system security, fraud prevention, and service improvement, with due regard for the rights and freedoms of the data subject.
  • Protection of vital interests: where necessary to protect the life or health of the data subject or another person.

3. How We Use Your Information

We use the information we collect to:

3.1 Provide the Service

  • Create and manage your account.
  • Process transactions and payments.
  • Store and manage your business data.
  • Provide customer support services.
  • Send important notifications related to the Services.

3.2 Improve the Service

  • Analyse usage to improve features.
  • Conduct product research and development.
  • Personalise the user experience.
  • Identify and fix bugs.

3.3 Communicate With You

  • Send transactional emails (payment confirmations, invoices).
  • Provide information about product updates and new features.
  • Send newsletters and educational content with your consent.
  • Deliver promotional information and special offers.

3.4 Security and Compliance

  • Prevent fraud and unlawful activity.
  • Protect the security of the system and users.
  • Comply with legal obligations and applicable laws and regulations.
  • Resolve disputes and enforce agreements.

4. Sharing of Information

We do not sell your personal data. We only share information in the following circumstances:

4.1 Third-Party Service Providers

We work with trusted service providers to support our operations:

  • Payment gateway: to process payments (Xendit).
  • Cloud hosting: to store data (Supabase, AWS).
  • Email services: to send transactional emails.
  • Analytics: to understand usage patterns of the service (Google Analytics).

All such service providers are bound by confidentiality and data protection agreements with PAWSI.

4.2 Legal Obligations

We may disclose information where required by law, including to:

  • Respond to court orders or applicable legal process.
  • Comply with official requests from competent government authorities.
  • Protect the rights and safety of PAWSI, users, or the public.
  • Detect, prevent, or address fraud and security issues.

4.3 Change of Ownership

If PAWSI is involved in a merger, acquisition, or asset transfer, your information may be transferred as part of that transaction. We will notify you in advance if your information is transferred and becomes subject to a different privacy policy.

5. Data Security

We implement technical and organisational security measures to protect your data:

5.1 Technical Security

  • Encryption: sensitive data is encrypted in transit (HTTPS/TLS) and at rest.
  • Firewall: protects the network and systems from unauthorised access.
  • Authentication: a secure login system with email verification.
  • Backups: automatic daily backups for data recovery purposes.
  • Monitoring: 24/7 monitoring to detect suspicious activity.

5.2 Organisational Security

  • Access to data is restricted to employees who need it.
  • All employees sign confidentiality agreements.
  • Security training is conducted periodically for internal teams.
  • Security audits are conducted periodically by an independent third party.

5.3 User Responsibility

You also share responsibility for keeping your account secure, including by:

  • Using a strong and unique password.
  • Not sharing your login credentials with others.
  • Logging out after using a shared computer.
  • Promptly reporting to us if you suspect unauthorised access.

6. Data Storage and Retention

6.1 Storage Location

Your data is stored on secure cloud servers located within the territory of the Republic of Indonesia, in accordance with Government Regulation No. 71 of 2019 on the Implementation of Electronic Systems and Transactions for Private Scope Electronic System Operators.

6.2 Retention Period

We retain your data following retention stages aligned with Section 8.3 of the Terms and Conditions and Section 7.3 of the Subscription Terms:

  • While your subscription is active: all business data remains fully stored and accessible to you via the dashboard.
  • Days 1–30 after cancellation/expiry of the subscription: the account is placed in read-only mode for recovery and data export.
  • Days 31–60 after cancellation: login access is disabled; data remains stored for recovery upon written request.
  • After day 60: data is permanently deleted, except for data that must be retained longer under applicable laws and regulations.
  • Data resulting from a plan downgrade: may be retained for up to 90 days in read-only mode as set out in Section 6 of the Subscription Terms.

6.3 Legal Obligations

We may retain some data longer to meet the following needs:

  • Tax compliance (at least 10 years in accordance with Indonesian tax regulations).
  • Dispute resolution or legal investigation processes.
  • Fraud prevention.

7. Your Rights as a Personal Data Subject

In accordance with the UU PDP and its implementing regulations, you have the following rights as a personal data subject:

7.1 Right of Access

You have the right to know what personal data we hold about you and to request a copy of it.

7.2 Right of Correction

You may update or correct inaccurate information via your account dashboard or by contacting us.

7.3 Right of Erasure

You may request the deletion of your personal data, except for data we are required to retain for legal compliance.

7.4 Right to Data Portability

You may export your business data in a machine-readable format (CSV or Excel) at any time via the dashboard.

7.5 Right to Withdraw Consent

Pursuant to Article 9 of the UU PDP, you have the right to withdraw your consent to the processing of your personal data at any time, whether for marketing communications or other processing carried out on the basis of consent. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn. You may withdraw consent via:

  • Clicking “Unsubscribe” on our marketing emails.
  • Changing your notification preferences in the dashboard.
  • Contacting us at [email protected].

7.6 Right to Object to Processing and Automated Decision-Making

Pursuant to Article 9 of the UU PDP, you have the right to object to the processing of personal data carried out on the basis of legitimate interest, and to object to being subject to a decision based solely on automated processing that produces legal effects or significantly affects you. Contact [email protected] to raise an objection.

7.7 Right to Lodge a Complaint

If you believe your rights over your personal data have not been fulfilled, you have the right to lodge a complaint with PAWSI via [email protected] and/or with the Personal Data Protection Agency (Lembaga Pelindungan Data Pribadi, “LPDP”) or other competent authority in accordance with the UU PDP.

7.8 How to Exercise Your Rights

To exercise the rights above, please contact us at [email protected] including:

  • Your full name and the email registered to your account.
  • A description of the right you wish to exercise.
  • Proof of identity verification, to protect your privacy.

In accordance with the UU PDP, we will respond to requests relating to the rights of access, correction, and withdrawal of consent within 3×24 hours (72 hours), and to other requests within 14 (fourteen) working days.

8. Cookies and Tracking Technologies

8.1 Types of Cookies We Use

  • Essential cookies: required for basic system functions, such as login and security.
  • Functional cookies: store your preferences, such as language and display theme.
  • <strong>Analytics cookies:</strong> help us understand how you use the service (Google Analytics).
  • <strong>Marketing cookies:</strong> used to display relevant advertising, with your consent.

8.2 Managing Cookies

You can manage cookies through:

  • Your browser settings, to block or delete cookies.
  • The cookie banner that appears the first time you visit our site.

Note: disabling essential cookies may affect the basic functioning of the service.

9. Children's Privacy

PAWSI's services are intended for business purposes and are not designed for children under the age of 18. We do not knowingly collect personal data from children. If you become aware that we hold data from or about a child under the age of 18, please contact us immediately so it can be deleted.

10. International Data Transfers

Your personal data is stored on servers located within the territory of the Republic of Indonesia. In certain cases, some supporting service providers (e.g. transactional email or analytics services) may process data from jurisdictions outside Indonesia. Pursuant to Article 56 of the UU PDP, any transfer of personal data outside the territory of Indonesia is only carried out where:

  • The recipient country has a level of personal data protection equivalent to or higher than the UU PDP; or
  • There are adequate and binding personal data protections between the parties (binding contractual safeguards); or
  • The personal data subject has given consent.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. Material changes will be notified via:

  • Email to the address registered to your account.
  • In-app notification when you log in to the dashboard.
  • A notice on our official website.

You will be given at least 30 (thirty) days to review the changes before they take effect. Continued use of the services after the changes take effect indicates your agreement to the revised policy.

12. Governing Law

This Privacy Policy is governed by and construed in accordance with:

  • Law No. 27 of 2022 on Personal Data Protection (UU PDP).
  • Implementing regulations of the UU PDP and Regulations of the Ministry of Communication and Informatics relating to personal data protection.
  • Other applicable laws and regulations of the Republic of Indonesia.

13. Notification of Personal Data Protection Failure

Pursuant to Article 46 of the UU PDP, in the event of a personal data protection failure, we will:

  • Notify affected personal data subjects in writing no later than 3×24 hours (72 hours) after we become aware that the failure has occurred.
  • Report the failure to the Personal Data Protection Agency (LPDP) and/or other competent authorities within the same period.
  • Provide information on the type of personal data disclosed, when and how the failure occurred, and the handling and recovery measures taken.
  • Where the failure has a broad impact on the public interest, we will also announce the failure in accordance with Article 46 paragraph (3) of the UU PDP.

14. Contact Us and the Personal Data Protection Officer

If you have questions about this Privacy Policy or wish to exercise your rights relating to personal data protection, please contact us:

Pursuant to Article 53 of the UU PDP, PAWSI has appointed a Personal Data Protection Officer responsible for ensuring compliance with the UU PDP, providing advice on the impact of processing, and acting as a point of contact for data subjects and competent authorities.

By using PAWSI's services, you acknowledge that you have read and understood these terms and agree to be bound by them.

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