Privacy Policy
1. Who We Are
FRAYM is an independent project-based construction and development advisory operating in Bali, Indonesia.
For the purposes of Law No. 27 of 2022 on Personal Data Protection (UU PDP) of the Republic of Indonesia, FRAYM acts as the Data Controller for personal information collected through this website and related communications.
This means we determine:
What data is collected
Why it is collected
How it is used
How long it is retained
Even during our MVP operational stage, we are committed to handling personal data in accordance with recognized international standards and Indonesian legal requirements.
2. Purpose of This Privacy Policy
This Privacy Policy explains:
What information we collect
Why we collect it
How we process and protect it
When we may share it
What rights you have
What our legal limitations are
It applies to:
Website visitors
Prospective clients
Investors
Contractors
Business partners
By using this website or submitting information to us, you acknowledge and agree to this policy.
3. What Information We Collect
We collect only information that is reasonably necessary to provide services or evaluate potential collaboration.
A. Identification & Contact Information
Full name
Email address
Phone number
Nationality
Company name (if applicable)
B. Technical Information
When you visit our website, we may automatically collect:
IP address
Device type
Browser type
Pages visited
Interaction duration
Cookies and analytics data
This helps us understand website performance and improve user experience.
C. Project & Investment Information
If you contact us regarding a villa or development project, we may receive:
Land details
Budget range
Architectural drawings
Structural concepts
Financial expectations
Contractor discussions
This information is treated as confidential business data.
We do not intentionally collect sensitive personal data (such as medical, biometric, or religious information).
4. Why We Collect Your Data
We process personal information for legitimate business purposes, including:
Responding to inquiries
Preparing project proposals
Evaluating construction feasibility
Coordinating with architects and engineers
Structuring development strategies
Improving operational systems
Complying with legal obligations
Protecting our legal position in case of disputes
We do not sell, rent, or trade personal data.
5. Legal Basis Under Indonesian Law (UU PDP)
Under Indonesia’s Personal Data Protection Law, personal data must have a lawful basis for processing. We rely on:
Your explicit consent
Pre-contractual necessity (e.g., preparing proposals)
Legitimate business interest
Compliance with legal requirements
You may withdraw consent at any time, subject to contractual or legal limitations.
6. Cross-Border Data Transfers
Because many of our investors and consultants are international, your information may be processed or stored outside Indonesia.
Where this occurs, we ensure:
Transfers are made in good faith
Reasonable security standards are applied
Data is shared only for legitimate operational purposes
By engaging with us, you acknowledge and accept this possibility.
7. How We Share Information
We may share limited information strictly when necessary with:
Structural engineers
Architects
Quantity surveyors
Contractors
Legal or accounting advisors
IT and hosting providers
We do not grant unrestricted access to third parties.
However, once data is shared for legitimate project execution, we are not responsible for independent actions taken by those third parties beyond our reasonable control.
8. Data Retention
We retain personal data only for as long as necessary to:
Complete project evaluations
Fulfill contractual obligations
Maintain accounting records
Protect against legal claims
Comply with Indonesian regulations
After that period, data may be deleted, anonymized, or securely archived.
9. Data Security
We implement reasonable safeguards, including:
Secure digital storage
Restricted access controls
Password-protected systems
Structured internal communication channels
Despite these efforts, no digital system is completely immune from risk.
By transmitting information electronically, you acknowledge inherent cybersecurity risks that may exist globally.
10. Limitation of Liability (Data-Related)
To the fullest extent permitted under Indonesian law:
FRAYM shall not be liable for:
Indirect or consequential damages
Loss of anticipated profits
Cyber incidents beyond reasonable control
System failures of third-party providers
Unauthorized access caused by user negligence
Force majeure events (natural disasters, system-wide outages, regulatory restrictions)
Nothing in this clause excludes liability where such exclusion is prohibited by Indonesian law.
11. No Automatic Professional Engagement
Submission of personal information or project data through this website does not:
Create a binding contract
Establish a fiduciary relationship
Create engineering responsibility
Form a construction obligation
Professional obligations arise only after a formal written agreement is executed.
12. Your Rights
Subject to Indonesian law, you may:
Request access to your personal data
Request correction
Request deletion
Withdraw consent
Object to certain processing activities
Requests may be submitted via: [Insert Email]
We reserve the right to verify your identity before processing such requests.
13. Governing Law & Dispute Resolution
This Privacy Policy is governed by the laws of the Republic of Indonesia.
Any disputes arising in relation to data protection shall be resolved in good faith negotiation. If unresolved, disputes shall fall under the jurisdiction of Indonesian courts unless otherwise agreed in writing.
14. Policy Updates
We may update this Privacy Policy periodically.
The latest version will always be available on this website with an updated effective date.
Continued use of the website indicates acceptance of revisions.