This Privacy Policy explains how PT SDP Gateway Global ("we", "us", "our"), trading as Bali Way Solutions, collects, uses, stores, and protects your personal data when you use our website baliwaysolutions.org or engage our visa facilitation services.
We are committed to complying with Indonesia's Personal Data Protection Law (Law No. 27 of 2022, "PDP Law") and other applicable data protection regulations.
1. Who We Are
- Data Controller: PT SDP Gateway Global
- Trading name: Bali Way Solutions
- Business Registration (NIB): 0405260072936
- Registered office: Jl. Kecapi Mas Raya No. 28, Desa/Kelurahan Kalijaga, Kec. Harjamukti, Kota Cirebon, Provinsi Jawa Barat, Indonesia
- Contact for privacy matters: sdpgateglo@atomicmail.io
2. What Data We Collect
To facilitate your visa application, we collect and process the following categories of personal data:
Identity and contact data:
- Full name, date of birth, place of birth, nationality
- Passport details (number, issue date, expiry date, scanned copies)
- Residential address, email address, telephone number
- Photographs meeting Indonesian immigration specifications
Application-supporting data:
- Employment status, occupation, employer details
- Financial information required by immigration authorities (e.g. bank statements, proof of funds, sponsor letters)
- Travel history and itinerary details
- Marital status and family information where required by visa type
- Educational qualifications and professional credentials where required
- Health declarations where required by visa type
Transaction data:
- Records of services purchased, fees paid, refunds issued
- Bank transfer details and payment confirmations (we do not store full bank account numbers beyond what is necessary for transaction records)
Technical data:
- IP address, browser type, device information
- Website usage data via cookies (see Section 8)
We do not knowingly collect data from anyone under 18 except where required for a family visa application submitted by a parent or legal guardian.
3. How We Collect Your Data
We collect personal data directly from you when you:
- Submit an enquiry through our website
- Engage us to facilitate a visa application
- Provide supporting documents at our request
- Communicate with us by email, phone, or messaging platforms
We may also receive data about you from third parties, including your sponsor, employer, family members applying jointly, or your legal representative, where they provide it for the purpose of your visa application.
4. Why We Collect Your Data (Legal Basis)
We process your personal data on the following legal bases under the PDP Law:
- (a) Contract performance: To deliver the visa facilitation services you have engaged us for.
- (b) Legal obligation: To comply with Indonesian immigration regulations, tax laws, and anti-money-laundering requirements.
- (c) Consent: Where you have given explicit consent for specific processing activities, such as marketing communications.
- (d) Legitimate interest: For internal record-keeping, fraud prevention, and improving our services.
5. Who We Share Your Data With
We share your personal data only with parties necessary to deliver our services:
- (a) Indonesian government authorities: Including the Directorate General of Immigration (Direktorat Jenderal Imigrasi), the Ministry of Law and Human Rights, and any other authority required to process your visa application. This is mandatory and cannot be opted out of if you proceed with an application.
- (b) Sponsors and guarantors: Where your visa type requires a sponsor, we may share relevant details with them for the purpose of obtaining sponsorship documentation.
- (c) Service providers: Including secure document storage providers, email services, and accounting providers who assist us in operating our business. These providers are bound by confidentiality obligations.
- (d) Legal and professional advisers: Where necessary to obtain legal, tax, or accounting advice.
- (e) Law enforcement and regulators: Where required by Indonesian law or a valid court order.
We do not sell your personal data to any third party.
6. International Data Transfers
Some of our service providers (including email, cloud storage, and communication platforms) are based outside Indonesia. Where personal data is transferred outside Indonesia, we ensure such transfers comply with Article 56 of the PDP Law, including by:
- Transferring to jurisdictions with adequate data protection standards, or
- Putting in place contractual safeguards with the receiving party, or
- Obtaining your explicit consent where required.
You acknowledge that submitting your data to us may involve such cross-border transfers.
7. How Long We Keep Your Data
We retain your personal data for the following periods:
- Active client files: For the duration of your engagement and any subsequent visa validity period.
- Completed application records: 5 years after service completion, to meet Indonesian tax record-keeping requirements and to respond to any later queries from immigration authorities.
- Financial transaction records: 10 years, as required by Indonesian tax and accounting law.
- Marketing data: Until you withdraw consent.
After these periods, we securely delete or anonymise your data.
8. Cookies
Our website uses cookies to:
- Enable essential website functionality
- Measure website performance and usage
- Remember your preferences
You can disable cookies through your browser settings. Disabling essential cookies may prevent parts of the website from working correctly.
9. Your Rights Under the PDP Law
You have the following rights regarding your personal data:
- (a) Right to be informed about how your data is processed.
- (b) Right to access the personal data we hold about you.
- (c) Right to correct inaccurate or incomplete data.
- (d) Right to delete your data, subject to our legal retention obligations.
- (e) Right to withdraw consent for processing based on consent.
- (f) Right to object to certain types of processing.
- (g) Right to data portability where technically feasible.
- (h) Right to lodge a complaint with the Indonesian data protection authority.
To exercise any of these rights, contact us at sdpgateglo@atomicmail.io. We will respond within 72 hours and complete your request within 30 days, in line with the PDP Law.
Note: Some rights are limited where your data is required by immigration authorities or by law. We cannot, for example, delete data that immigration regulations require us to retain.
10. How We Protect Your Data
We apply reasonable technical and organisational measures to protect your data, including:
- Encrypted storage of sensitive documents
- Restricted access on a need-to-know basis
- Secure transmission channels for document handling
- Regular review of our security practices
However, no system is completely secure. You acknowledge that you submit data to us at your own risk and that we cannot guarantee absolute security against all threats.
11. Data Breach Notification
In the event of a personal data breach that poses a risk to your rights and interests, we will notify you and the relevant authorities within 72 hours of becoming aware of the breach, as required by Article 46 of the PDP Law.
12. Changes to This Policy
We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects the most recent version. Material changes will be communicated to active clients by email.
13. Contact Us
For any questions, requests, or complaints regarding your personal data:
PT SDP Gateway Global (Bali Way Solutions)
Email: sdpgateglo@atomicmail.io
Address: Jl. Kecapi Mas Raya No. 28, Desa/Kelurahan Kalijaga, Kec. Harjamukti, Kota Cirebon, Provinsi Jawa Barat, Indonesia
