Privacy Policy

1. Introduction

Welcome to the JALA platform operated by PT Jala Akuakultur Lestari Alamku, its affiliates, and subsidiaries (collectively or individually referred to as “JALA” or “we/us”). This Privacy Policy explains how we carry out the collection, processing, analysis, storing, correction, updating, displaying, disclosing, transferring, disseminating, deletion, and destroying of your Personal Data (“Process Personal Data” or engage in “Personal Data Processing”).

We acknowledge that the protection of Personal Data is of utmost importance. We are committed to maintaining the confidentiality, integrity, and security of your Personal Data in accordance with applicable laws and regulations.

We shall only engage in Personal Data Processing for legitimate purposes and in line with the consent you have provided, and we ensure that appropriate measures have been taken to safeguard your data from unauthorized access, alteration, or misuse.

2. Definition

In this Privacy Policy, the following words and expressions shall have the following meanings respectively ascribed to them:

“Account” means the personal profile or credentials you create when registering for or using our platform. This includes information such as your username, password, contact details, and any other information associated with your registration and use of the platform.

“Baruni” means a hardware device used to measure the water quality of aquaculture farms.

“Personal Data” means any data and information regarding an identified or identifiable information of any individual, either on its own or in combination with other information, whether directly or indirectly, through electronic or non-electronic systems.

“Specific Personal Data” means Personal Data that, when processed, may have a greater impact on individuals including health data and information, biometric data, genetic data, criminal records, children's data, personal financial data, and other data as required by applicable laws.

“General Personal Data” means Personal Data that includes the following: full name, gender, nationality, religion, marital status, and/or other Personal Data that can be combined to identify an individual.

“Aggregate Information” means data that is collected from a number of individuals and combined and therefore it cannot be used to identify any individual. This information is statistical in nature and used to analyze trends, patterns, and preferences. Aggregate Information is not considered Personal Data because it does not contain any personally identifiable information.

“JALA App” means the shrimp farming management application and shrimp farming licensing compliance level assessment.

“Services” means JALA App, the official website of JALA, all applications owned or produced by JALA, and any programs organized by JALA.

“Business Identification Number, hereinafter referred to as NIB,” means proof of registration for conducting business activities and serves as an identification for individuals or entities in carrying out their business activities.

“OSS-RBA” means an application developed and owned by the Government of the Republic of Indonesia through the relevant ministry, which serves as a platform for the public to apply for and obtain business licenses.

“Customer” means individuals, legal entities, or companies that use the Services.

“Profiling” means any type of automated processing of Personal Data, which includes the use of such data to evaluate, analyze, or predict various personal aspects concerning an individual. This may specifically involve assessments related to the individual's performance in their workplace, their economic circumstances, physical and mental health, personal preferences, interests, reliability, behavior patterns, location, or movements.

“Third Party” means any party other than us, our affiliates, and our subsidiaries that process Personal Data.

“Product” means Baruno and other hardware that we own or manufacture.

By agreeing to this Privacy Policy, you acknowledge that you have read, understood, and agreed to this Privacy Policy.

You hereby consent to us engaging in your Personal Data Processing as described in this Privacy Policy.

Suppose you provide the Personal Data of another individual. In that case, you represent that you have obtained their consent to share such information with us and for it to be processed following this Privacy Policy.

You have the right to withdraw your consent at any time, with the understanding that withdrawing consent will result in your inability to use our Services any more.

4. Data Collection

As permitted by applicable law, we collect, as a controller or processor of Personal Data, in the manner outlined below:

4.1 Collected Personal Data

Identity Data includes full name, residential address, phone number, email address, identification or passport number, and photo.
Financial Data includes harvest sales, farm capital, receivables, credit assessment data, and expenses such as seeds and shrimp post-larvae, chemical products, feed, farm facilities and infrastructure, probiotics, gasoline, farm construction, salaries, electricity, farm preparation, land rental/lease, as well as other necessary income and expenses in shrimp farm management.
Payment Data includes account numbers, debit or credit card information, and other data required by the Third Parties to Process your Personal Data.
Location Data includes real-time geographic location data, the place where you use the Product, and the location of your shrimp farm.
Water Quality Data includes the results of shrimp farm water quality measurements such as pH, salinity, dissolved oxygen, temperature, electrical conductivity, total dissolved solids, seawater gravity, turbidity, ammonia, nitrate, nitrite, alkalinity, and other water quality indicators to enable shrimp farms to monitor their farms.
Cultivation Data includes daily feed consumption, shrimp samples such as average weight, size or quantity of shrimp, total and partial harvest times, total biomass, shrimp prices, survival rates, farm area, farm depth, the start time and the end time of the cultivation cycle, total shrimp seed, number of farms/blocks/ponds, feed brands, seed brands, and administration of other chemicals, weather, and other data that affects cultivation.
Record Data includes IP address, browser type and language, device type, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time of each request you make.
Technical Data includes the date and time of Product usage, as well as technical information necessary for operating the Product.

4.2 Use of Personal Data

We may engage in your Personal Data Processing for the following purposes (“Purposes”):

to administer your Account on the JALA App;
to fulfill your orders for Products and Services;
to communicate with you;
to assist you in using the Products and Services;
to monitor the use of the Services;
to improve the Services or Products and to develop and test new Products and Services;
to provide you with information about Products and Services (including Third Party products and services);
to send you emails, notifications, text messages, or other communications related to your use of the Services, your Account, the Product you have ordered, or to respond to your inquiries or requests. You may not opt out of receiving non-promotional emails related to the provision of Services;
send promotional emails to provide notifications about products or services that may be of interest to you. If you wish to stop receiving promotional messages from us or any Third Parties, please click the unsubscribe link in the non-Service-related emails that you receive;
engage in your Personal Data Processing to comply with applicable law;
to create and develop Aggregate Information from the Personal Data we collect from you. Aggregate Information cannot be used to identify you, and therefore, Aggregate Information is not considered as Personal Data;
to use Aggregate Information to analyze trends, manage the Services, track your movements, develop new Products or Services for research purposes, or improve our business and Services;
to share Aggregate Information with Third Parties to develop and deliver targeted advertisements to analyze and report on the advertisements you view; and
to share Aggregate Information with our business partners.

4.3 Personal Data of People with Disabilities

In the event that you are an individual with a disability, by agreeing to this Privacy Policy, you affirm that you have the ability to read and fully understand this Privacy Policy. Where required by applicable law, you are either a parent or legal guardian representing the individual with a disability whose Personal Data will be processed by us.

We are fully committed to providing Services and Products to assist individuals with disabilities. If you experience any difficulties or challenges in using our Services and Products, please contact us immediately using the details provided in the "Contact Us" section.

4.4 Child Personal Data

The Services are not intended for children under the age of 17. We do not intentionally carry out any collection or storing of any Personal Data or non-personal information from anyone under 17 years of age. Our Products and Services are not directed to children under the age of 17.

As a parent or legal guardian, please do not provide authorization for a child under your care to provide Personal Data to us.

In the event that the Personal Data of a child under the age of 17 under your care is disclosed to us, you hereby agree to be bound by this Privacy Policy on behalf of that child.

We shall terminate any Account that is used exclusively by such children and shall remove and/or delete any Personal Data that we believe was submitted to us without the consent of the parent or legal guardian by a child under the age of 17.

5. Data Storing

We shall only retain your Personal Data collected in accordance with the Purposes and other provisions of this Privacy Policy.

JALA shall remove your Personal Data immediately when we reasonably consider that the Personal Data that has been collected is no longer necessary to fulfill the Purposes or that storage is no longer necessary to meet our business needs or to comply with the applicable legal requirements (“Retention Period”).

In addition, we will also delete your Personal Data from our system no later than 3 (three) years from the time your Account is deleted.

6. Data Processing and Analysis

6.1 Safety of Personal Data

We ensure that only certain authorized employees are permitted to engage in your Personal Data Processing. Additionally, we implement a One Time Password ("OTP") feature in the JALA App to ensure that only you or certain individuals you designate can access your Account. In addition, we take other measures to protect the confidentiality of your Personal Data in accordance with applicable laws.

In the event that our Services include links to sites outside of those we control or own, we are not responsible for the privacy policies or practices of those other sites.

We do not provide warranties that we have an absolute system that can fully prevent or mitigate the risk of Personal Data breaches or unauthorized access to the Personal Data that we control or process.

6.2 Record

We are committed to ensuring transparency and accountability in engaging in your Personal Data Processing and therefore, we record and document all activities, including:

Personal Data that we will process or control;
Records of the purposes for processing your Personal Data, in accordance with the provisions described in this Privacy Policy;
Security measures taken to prevent unauthorized access or processing of your Personal Data, including encryption, restricted access, and other precautions to ensure the security and integrity of the data;
Records of the duration for which Personal Data will be stored, in accordance with the Retention Period set by applicable law or as stipulated in this Privacy Policy; and
Any deletion, anonymization, or modification of Personal Data, including preparation of your Personal Data into Aggregate Information, will be appropriately documented.

JALA may provide you with access to your Personal Data that we process, including with a record of your Personal Data Processing, as long as we retain the Personal Data.

We shall provide this access to you no later than 72 work hours after we receive a request for access from you.

6.3 Suspension and Restriction

You may submit a request for suspension and restriction of Personal Data Processing to us proportionally if you believe that your Personal Data that we process is inaccurate, the Personal Data that you provide to us is inaccurate, and/or the Personal Data Processing that we carry out is unlawful. We may accept such a request for suspension and restriction if we consider that based on reasonable grounds, you have fulfilled the reasons mentioned above.

We will suspend and restrict the Personal Data Processing no later than 48 hours after we receive the request to suspend and restrict the Personal Data Processing.

We may reject your request for suspension and restriction of Personal Data Processing if there are any provisions of applicable legal regulations that prevent such suspension and restriction of Personal Data or if it may endanger the safety of any party.

In the event that we reject your request to suspend or restrict your Personal Data Processing, we will notify you as soon as possible and provide the reasons for this. Suspension and restrictions on Personal Data Processing result in you not being able to use our Services.

7. Correction or Update

You may submit a request for correction or update your Personal Data contained in our system. The request for correction or update of Personal Data must include which Personal Data is to be corrected or updated as well as provide the corrected or updated Personal Data. We will correct or update your Personal Data in our system no later than 72 hours after receiving your request. We reserve the right to deny your request for access or correction of your Personal Data if:

it endangers the security, physical health, or mental well-being of yourself and/or another individual;
it impacts the disclosure of another individual’s Personal Data; and/or
it is contrary to national defense and security interests

8. Disclosure, Announcement, and Transfer

We may disclose your Personal Data in the following cases:

to the Third Parties to fulfill the Purpose;
to any relevant parties in the event we are going to receive investments or engage in acquisitions, mergers, divestitures, and consolidations with any other companies; and
to the government institutions or state agencies to comply with applicable laws, and protect the property, rights, or personal safety of JALA, you, users of JALA's Service and Product, and/or the public.

We ensure that your Personal Data Processing, whether in part or in full, by the Third Parties is subject to the provision stipulated in this Privacy Policy. We may also announce your Personal Data to the public if you voluntarily submit feedback, content, or other information to a public part of our platform (including forums, social media, or public reviews), and therefore such information is available to the public.

We do not announce your Personal Data to the public without explicit consent from you, unless required or permitted by law. However, under specific circumstances, such as legal obligations, compliance with regulatory requirements, or lawful requests from government authorities, we may be required to disclose Personal Data to the public.

In such cases, we ensure that any public announcement is strictly limited to what is necessary to fulfill the legal obligation or requirement.

We take all reasonable measures to protect your privacy and ensure that such announcement is handled in a secure and transparent manner, in accordance with the provision of applicable data protection laws.

Additionally, any public announcement of Personal Data that is intended for marketing, promotional, or other business-related purposes will only occur with your prior consent, and we will inform you of the purpose and scope of such announcement.

We may carry out transfer of Personal Data to any Third Party for Personal Data Processing or provide services on our behalf. In the event that the Personal Data is transferred outside or in Indonesia, we ensure adequate safeguards are in place to protect your Personal Data. This includes implementing technical measures by the recipient of your Personal Data and agreeing to a data disclosure agreement, Personal Data Processing agreement, or standard contractual clauses such as this Privacy Policy.

We hereby warrant that the transfer of your Personal Data abroad or domestically is in accordance with this Privacy Policy and applicable laws.

9. Deletion and Destruction

9.1 Cessation

We shall cease your Personal Data Processing when the Retention Period has expired, the Purpose has been achieved, or based on your request to cease the Personal Data Processing. If the cessation of your Personal Data Processing occurs due to your request, we will acknowledge and carry out the request no later than 72 hours from the receipt of your request.

You should understand that the cessation of your Personal Data Processing means that you will no longer be able to use our Services and Products.

9.2 Deletion

We may delete your Personal Data from all of our systems if the Purpose has been achieved, you withdraw your consent for the Processing of Personal Data, upon your request, or if the Personal Data was obtained and/or processed unlawfully. For the avoidance of doubt, deletion refers to the process by which your Personal Data is rendered inaccessible to you or any other party in general.

You should understand that the deletion of your Personal Data from all our systems means that you will no longer be able to use our Services and Products. Additionally, we will retain and possess Aggregate Information that was previously created before or at the time of the deletion of your Personal Data.

9.3 Destruction

We may destroy your Personal Data if the Retention Period has expired, based on your request, if it is not related to the resolution of any legal proceedings, and/or if the Personal Data was obtained and/or processed unlawfully. For the avoidance of doubt, destruction refers to a process that makes the Personal Data inaccessible, unrecoverable, or unusable by any party in any manner.

You should understand that the destruction of your Personal Data from all our systems means that you will no longer be able to use our Services and Products. Additionally, we will retain and possess Aggregate Information that was previously created before or at the time of the destruction of your Personal Data.

10. Compensation

You have the right to compensation in the event of a violation of the processing of Personal Data in accordance with applicable legal provisions.

11. Limitation of Liability

To the maximum extent permitted by applicable law, JALA shall not be liable for any indirect damages or punitive damages, including loss of profits or other intangible losses, arising out of or in connection with:

any leakage of your Personal Data which is not caused by our fault or negligence;
disruptions or interruptions in the transmission to or from our Services, including - bugs, viruses, or other malicious software that may be transmitted to or through our Services by any party;
failure to comply with applicable laws, regulations, or other obligations arising from the use of our Services or Products or reliance on any information provided herein; and
any actions by any party using our Services or Products to cause harmful damages to any other party or commit a criminal act.

Our total liability for any claim arising from or related to the use of our Services and/or Products by you shall not exceed the total amount you have paid.

12. Right to Access

You have the right to receive a copy of the Personal Data you have provided to us free of charge unless otherwise specified with prior notice to you.

13. Limitations of Personal Data Processing

Your rights related to Personal Data arising from applicable laws or this Privacy Policy do not apply to:

national defense and security;
law enforcement processes;
public interest for the state administration;
supervision of the financial services sector, monetary policy, payment systems, and financial system stability conducted for state administration purposes; and/or
statistical and scientific research purposes.

14. Right to Data Portability

You have the right to data portability, which enables you to obtain and reuse your Personal Data for your own purposes across different services.

This right enables you to receive and/or utilize the Personal Data that you have provided to us in a structured, commonly used, and machine-readable format. You can also request that we transmit this data directly to another service provider, where technically feasible.

This right to data portability empowers you to manage and move your Personal Data across various platforms and services, facilitating the seamless use of your data without losing information.

This right applies only to Personal Data you have actively provided to us (does not include Aggregate Information), Processed and stored electronically, as well as only relates to your Personal Data.

If you wish to exercise your right to data portability, please contact us using the details provided in the ‘Contact Us’ section of this Privacy Policy.

We will respond to your request in a timely manner and ensure the secure transfer of your data where possible.

15. Profiling

JALA engages in Profiling through the automatic collection of Personal Data, which is stored in log files for analysis and tracking purposes. We utilize services such as Mixpanel, Posthog, Google Analytics, and other Third Parties providers. The types of Personal Data collected include, IP addresses, browser types, language preferences, device types, websites or URLs previously visited, other browsing history, platform types, number of clicks, landing pages, cookie information, websites or pages you request or view along with the exact timestamps of these actions, and the duration spent on accessing specific sites.

The Personal Data collected through Profiling mechanisms is then processed and analyzed to better understand our customer base, operate our business more effectively, promote our Services and Products, and enhance the quality of our Services. This data analysis enables us to identify trends, Customer preferences, and behaviors, allowing us to customize our offerings, enhance the optimization of business operations, and provide targeted marketing as well as personalized Customer experiences.

You have the right to object to the Profiling we carry out by contacting us through the contact information that we have provided in the 'Contact Us' section. In the event that you choose to object Profiling that we carry out, please understand that you may no longer be able to utilize our Services or Products.

16. Applicable Law

This Privacy Policy is subject to the laws of the Republic of Indonesia, including regulations regarding the protection of personal data.

17. Language

This Privacy Policy is prepared in both Indonesian and English. In the event of any conflict or difference in interpretation between the Indonesian and English versions, the Indonesian version shall prevail.

18. Contact

If you have any questions or suggestions regarding this Privacy Policy or in connection with submitting a request regarding your rights under this Privacy Policy, please contact us at contact@jala.tech.

updated on March 2025