Effective Date: 17.08.2026

1. Introduction
PT VIP SEA VACATIONS, Registration No. 1706260047506, having its registered address at Jalan Veteran Gang Jempinis Nomor 17, Banjar Uma Kepuh, Desa/Kelurahan Buduk, Kec. Mengwi, Kab. Badung, Provinsi Bali, 80351, Indonesia (“PT VIP SEA VACATIONS”, “Company”, “we”, “us”, or “our”), respects your privacy and is committed to protecting personal data processed in connection with our real-estate services.
This Privacy Policy explains how we collect, use, store, disclose, and otherwise process personal data when you:

• visit or use our website;
• submit a property inquiry;
• request information concerning a property;
• arrange a property viewing;
• contact us by email, telephone, messaging service, social media or contact form;
• request real-estate brokerage, marketing, consulting, rental, sale, investment or property-management-related services;
• enter into negotiations or a transaction involving a property; or
• otherwise communicate or do business with us.

2. Personal Data Controller
For purposes of applicable Indonesian personal data protection legislation, the relevant personal data controller is:
PT VIP SEA VACATIONS
Registration No.: 1706260047506
Director: Melissa Wong Sher Li
Address: Jalan Veteran Gang Jempinis Nomor 17, Banjar Uma Kepuh, Desa/Kelurahan Buduk, Kec. Mengwi, Kab. Badung, Provinsi Bali, 80351, Indonesia
Email: sea.vac2026@gmail.com
Phone: 08135891254

3. Personal Data We May Collect
Depending on your interaction with us, we may collect:
Identification information: name, surname, date of birth, nationality, passport or identification information where reasonably required for a transaction.
Contact information: email address, telephone number, residential or correspondence address and messaging application details.
Property preferences: preferred location, property type, price range, intended use, number of bedrooms, lease period, purchase criteria and other information relating to your property search.
Transaction information: offers, reservation information, payment information, transaction history, invoices and records relating to property negotiations.
Compliance and due-diligence information: information reasonably necessary to verify identity, authority, legal capacity, source of funds or compliance with applicable laws where such verification is required.
Communications: emails, messages, inquiries, telephone records, complaints and other communications with us.
Technical information: IP address, browser type, device information, operating system, website activity, cookies and similar technical data.
We ask that you do not provide sensitive personal data unless it is reasonably necessary for the requested service or required by law.

4. How We Collect Personal Data
We may obtain personal data:

• directly from you;
• through our website or online forms;
• through email, telephone or messaging applications;
• from property owners, developers, agents or business partners;
• from publicly accessible sources;
• from professional advisers involved in a transaction; and
• automatically through website technologies such as cookies.

5. Purposes of Processing
We may process personal data to:

• respond to inquiries;
• identify suitable properties;
• provide property information;
• arrange viewings;
• communicate with property owners, developers, agents or counterparties;
• negotiate potential transactions;
• process reservations or service requests;
• prepare agreements and transaction documentation;
• provide customer support;
• verify identity where reasonably required;
• prevent fraud and misuse;
• comply with legal and regulatory obligations;
• maintain accounting and business records;
• improve our website and services;
• protect our legal rights;
• handle complaints and disputes; and
• send marketing communications where permitted by law.

6. Legal Basis for Processing
We process personal data where processing is necessary or permitted in accordance with applicable law, including where:

• you have given consent;
• processing is necessary to perform or prepare a contract with you;
• processing is necessary to comply with a legal obligation;
• processing is necessary to protect legitimate interests recognised by applicable law; or
• another lawful basis applies.

Where processing relies on consent, you may withdraw that consent subject to applicable legal requirements.

7. Disclosure of Personal Data
We may disclose relevant personal data to:

• property owners;
• property developers;
• authorised property agents or brokers;
• prospective contractual counterparties;
• notaries and PPATs;
• lawyers, accountants and tax advisers;
• banks and payment providers;
• IT, hosting and cloud-service providers;
• marketing and communication service providers;
• government authorities, regulators or law-enforcement authorities where required; and
• other persons where authorised by you or permitted by law.

We only disclose information reasonably necessary for the relevant purpose.

8. International Transfers
Some service providers, customers, investors, property owners or technology providers may be located outside Indonesia.
Where personal data is transferred internationally, we will take steps reasonably required under applicable Indonesian law to protect such data.

9. Data Retention
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including to:

• complete property transactions;
• maintain accounting and business records;
• resolve disputes;
• enforce agreements; and
• comply with applicable legal requirements.

When personal data is no longer required, it may be deleted, destroyed, anonymised or otherwise handled in accordance with applicable law.

10. Data Security
We implement reasonable organisational and technical measures intended to protect personal data against unauthorised access, disclosure, alteration, loss, misuse or destruction.
However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

11. Your Rights
Subject to applicable Indonesian law, you may have rights concerning your personal data, including the right to:

• request information about our processing;
• obtain access to your personal data;
• correct or update inaccurate data;
• supplement incomplete data;
• withdraw consent where processing relies on consent;
• request termination of certain processing;
• request deletion or destruction where applicable;
• object to certain automated processing;
• request restriction or postponement of processing where applicable;
• obtain or transfer certain personal data where legally available; and
• exercise other rights provided by applicable law.

Requests may be submitted to sea.vac2026@gmail.com.
We may request reasonable verification of identity before processing a request.

12. Marketing Communications
Where permitted by law, we may contact you regarding properties, investment opportunities or services that may interest you.
You may unsubscribe or ask us to stop marketing communications at any time.

13. Cookies
Our website may use cookies and similar technologies to:

• operate the website;
• remember preferences;
• analyse website traffic;
• improve functionality; and
• support marketing activities.

You may control cookies through your browser settings, although disabling certain cookies may affect website functionality.

14. Third-Party Websites
Our website may contain links to third-party websites, developers, booking systems, payment processors or social-media platforms.
We are not responsible for the privacy practices of independent third parties. Their own privacy policies apply to their processing activities.

15. Children
Our services are primarily intended for adults capable of entering into real-estate transactions. We do not knowingly seek to collect personal data from children unless necessary and legally authorised.

16. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in our services, technologies or legal requirements.
The updated version will become effective when published or otherwise communicated, subject to applicable law.

17. Contact
Questions, requests or complaints regarding personal data may be addressed to:

PT VIP SEA VACATIONS
Email: sea.vac2026@gmail.com
Phone: 08135891254
Address: Jalan Veteran Gang Jempinis Nomor 17, Banjar Uma Kepuh, Desa/Kelurahan Buduk, Kec. Mengwi, Kab. Badung, Provinsi Bali, 80351, Indonesia.