This Privacy Policy explains how PT Nusantara Platform Digital ("Provider", "we") processes Personal Data in the EstateOS service at app.estateos.nusantaraplatform.com. It is based on:
- Law No. 27 of 2022 on Personal Data Protection ("PDP Law");
- Government Regulation No. 33 of 2026 implementing the PDP Law ("GR 33/2026");
- Government Regulation No. 71 of 2019 on Electronic Systems and Transactions.
Terms used in this policy:
- "Manager": an estate management body that subscribes to EstateOS, such as an estate manager, developer, foundation, association, residents' association (RT/RW), or cooperative.
- "Resident": an owner or tenant of a unit in an estate run by a Manager.
The Indonesian version prevails if the two versions differ.
1. Our two roles
| Data | Provider's role | Who decides the purpose of processing |
|---|---|---|
| Manager account, contact, subscription, and billing data (Section 2) | Personal Data Controller | Provider |
| Estate data entered or collected by the Manager through EstateOS, such as residents, units, dues invoices, payments, complaints, and visitors (Section 3) | Personal Data Processor | The Manager, as Controller |
For the data in Section 3, we only process data on the Manager's instructions, in line with the subscription agreement and this policy.
Residents who want to exercise their rights should first contact their estate Manager. We help the Manager fulfil such requests. If the Manager cannot be reached, Residents may contact us (Section 9).
2. Data we control
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Name, email, phone number, and position of the Manager's officers or contact person; estate name and address | Creating the account and tenant, performing the agreement, sending service notices | Performance of contract | Subscription period + 5 years |
| Subscription and billing data: plan, number of units, invoices, subscription payment history, tax ID when needed for invoices | Billing and the Provider's tax obligations | Legal obligation | 10 years (General Tax Law, Art. 28(11)) |
| Support and demo-request communications (email/forms) | Handling questions, demos, and incidents | Performance of contract / legitimate interest | 2 years after the last communication |
| Manager account security records: login history, IP address, device (user agent) | Preventing abuse and investigating incidents | Legitimate interest | 1 year |
We do not use this data for advertising or sell it. The EstateOS app has no third-party trackers or analytics.
3. Data we process on behalf of Managers
EstateOS stores the following data in the Manager's tenant. Each tenant's data is kept separate from every other tenant.
- App users (officers, staff, and Residents):
- name, email, phone number, role, and account status;
- password, stored as a bcrypt hash that no one can read, including us.
- Residents and units:
- unit/block number;
- occupancy status (owner or tenant);
- move-in and move-out dates;
- resident documents uploaded by the Manager, such as copies of ID cards or lease agreements.
- Dues invoices and payments:
- invoices per unit and payment history;
- transfer receipts uploaded by Residents;
- the treasurer's verification notes;
- Virtual Account/QRIS numbers and transaction references for automatic payments;
- unit credit balances.
- Estate payment accounts: bank name, account number, and account holder name of the Manager.
- Estate services: complaints with photos, facility bookings, announcements, and assets with maintenance records.
- Visitors and access: visitor name and phone number, the unit visited, and check-in and check-out times.
- Estate finances: cash book, expenses, and reports.
- Security records: audit trail of data changes, IP address, and device (user agent).
During the subscription, the Manager decides which data is entered and how long it is kept.
After the subscription ends:
- the Manager may request an export of the data;
- tenant data is deleted no later than 90 days after the subscription ends;
- offsite backup copies expire within the following 30 days.
4. Payments
EstateOS supports two ways to pay dues:
- Manual transfer: Residents pay directly into the Manager's bank account and upload the transfer receipt.
- Automatic payment: Virtual Account or QRIS on a sub-account owned by the Manager at PT Nusa Satu Inti Artha (DOKU), a payment service provider licensed by Bank Indonesia.
We never hold Residents' dues.
Residents' card or bank account details never pass through or stay in EstateOS; DOKU and the bank or payment issuer handle the payment. For each payment request we send DOKU only what it needs: the unit label or name, the amount, and the invoice reference. For Managers' subscription payments we also send the contact person's name and email.
5. Where data is stored and who can access it
- Data is stored in Indonesia, in the Google Cloud Jakarta region (asia-southeast2).
- The database and uploaded files are backed up daily. Backups are kept on the server for 7 days and in Google Cloud Storage in Indonesia for 30 days.
- We use the following subprocessors:
| Subprocessor | Service | Data |
|---|---|---|
| PT Google Cloud Indonesia (Google Cloud) | Servers, storage, and backups | All data in Sections 2 and 3, at rest |
| Google Workspace (Google) | Notification emails (invoices, payment verification, password reset) and the support inbox | Name, email, notice content |
| PT Nusa Satu Inti Artha (DOKU) | Subscription payments and automatic dues payments | Data described in Section 4 |
- If WhatsApp notifications are enabled in the future, phone numbers and notice content will be sent through a WhatsApp Business provider. We will update this policy before that happens.
- Provider staff access is limited to people who need it for maintenance, backup, recovery, and technical support. Access goes through Google Cloud accounts with two-step verification and is logged.
- Platform admins may enter a tenant at the Manager's request to provide support (impersonation). Every such access is recorded in the audit trail.
- We disclose data to authorities only when the law requires it, and where possible we tell the Manager first.
- We do not transfer Personal Data outside Indonesian jurisdiction. If that ever becomes necessary, we will meet the transfer rules of the PDP Law and GR 33/2026 and tell Managers in advance.
6. Security
Our main security measures:
- all connections are encrypted with HTTPS;
- passwords are stored as hashes;
- login sessions are kept in HttpOnly cookies that scripts cannot read;
- sessions are revoked automatically when a password, role, or account status changes;
- login attempts are rate-limited;
- access rights depend on the role (Super Admin, Admin, Staff, Resident);
- Residents can only see their own unit and invoices;
- tenant isolation is checked on every request;
- an audit trail is kept;
- the database is not exposed to the internet;
- adding a new payment account requires password confirmation, and a new account only becomes active after a waiting period;
- daily backups are made, with offsite copies that cannot be deleted from the server.
7. Cookies and on-device storage
EstateOS uses only the cookie it needs to work: the login session cookie. Your browser also stores some non-secret information:
- your language choice;
- the last estate selected on the login page;
- session display information.
You can clear this information in your browser settings. We do not use advertising or tracking cookies.
8. Personal data breaches
- Data we control (Section 2): we notify the affected people and the competent authority in writing within 3 × 24 hours, as required by Article 46 of the PDP Law. The notice states which data was exposed, when and how it was exposed, and what we are doing to contain the breach and recover.
- Estate data (Section 3): we notify the Manager within 24 hours of becoming aware of the breach. This lets the Manager meet its duties as Controller, including notifying Residents.
9. Your rights
Under the PDP Law you have the right to:
- information about how your data is processed;
- access your data and obtain a copy;
- correct inaccurate data;
- withdraw consent, where processing is based on consent;
- request deletion or destruction of your data;
- suspend or restrict processing;
- object to processing;
- receive your data in a commonly used format.
Residents can view their account details under Profile and change their own password. To correct other details, such as name or phone number, contact your estate Manager. Requests about the data in Section 2 go to privasi@nusantaraplatform.com.
We verify your identity and respond within 3 × 24 hours of receiving the request, as required by GR 33/2026. If a right cannot be fulfilled because of a legal obligation, we explain why. One example is the Manager's duty to keep estate financial records.
10. Children
EstateOS is intended for estate officers and adult Residents. Managers must not create accounts for children without a parent's or guardian's consent.
11. Demo environment
The demo at demo.app.estateos.nusantaraplatform.com contains sample data only and is reset every day. Please do not enter real personal data there.
12. Changes
We will notify Managers of material changes through the app or by email at least 30 days before they take effect. The version and effective date are shown at the top of this document.
13. Contact
Personal Data Protection Officer, PT Nusantara Platform Digital · privasi@nusantaraplatform.com · Yogyakarta.
General questions and support: halo@nusantaraplatform.com.