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Privacy Policy
This Privacy Policy is one of three documents that together govern your relationship with Impactive when using our Website. Please also read: (1) our Website Terms of Use, which governs your access to and use of the Website; and (2) our Cookie Notice, which explains how we use cookies and similar tracking technologies. These three documents should be read together.
Legal Basis: This Privacy Policy is prepared in accordance with: (1) Law No. 27 of 2022 on Personal Data Protection (UU PDP); (2) Law No. 11 of 2008 as amended by Law No. 19 of 2016 on Electronic Information and Transactions (UU ITE); (3) Government Regulation No. 71 of 2019 on Electronic Systems and Transactions; and (4) the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) where applicable to users in the European Economic Area.
1. About This Policy
Impactive (‘Impactive’, ‘We’, ‘Us’, ‘Our’) is a digital agency registered in Indonesia, operating the website at impactive.id (‘Website’). This Privacy Policy explains what personal data we collect when you use the Website, why we collect it, how we use and protect it, and what rights you have in relation to it.
The Website is an informational company website. It does not support account creation, user login, or any form of transaction. The only means by which you provide personal data to us directly is through our contact enquiry form.
By using the Website, you acknowledge that you have been informed of how your personal data is processed in accordance with this Privacy Policy. Where we are required by law to obtain your consent before processing your personal data, we will request it separately.
2. Data Controller
Impactive is the data controller for all personal data collected through this Website. As data controller, we determine the purposes and means by which your personal data is processed.
For data protection enquiries, you may contact us at: info@impactiveagency.com or via the contact details in Section 12 of this Policy.
3. What Personal Data We Collect
We collect two categories of personal data when you use the Website:
When you submit an enquiry through the Website contact form, we collect:
- First name and last name
- Email address
- Phone number
This is the only form through which you directly submit personal data to us. We do not operate newsletter sign-ups, account registration, or any transactional data collection on the Website.
When you visit the Website, certain technical and usage data is collected automatically by the Website and by third-party tools we use to operate and analyse the Website. This may include:
- Your IP address and approximate geographic location derived from it
- Device type, browser type and version, and operating system
- Pages visited, time spent on pages, and navigation paths
- Referring URL (the page you came from before visiting our Website)
- Date and time of your visit
This data is collected through cookies and similar tracking technologies. It does not, on its own, identify you by name. For full details of the cookies and tools we use, please refer to our Cookie Notice at impactive.id/cookie-notice.
4. Why We Collect Your Data and Our Legal Bases
We only collect and process personal data where we have a lawful basis to do so. The table below sets out our purposes and the corresponding legal bases under UU PDP and, where applicable, the GDPR.
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Responding to your enquiry submitted via the contact form | Name, email address, phone number | Consent (UU PDP; GDPR Art. 6(1)(a)) |
| Analysing Website traffic and improving Website performance | Automatically collected technical and usage data | Legitimate interest (UU PDP; GDPR Art. 6(1)(f)) |
| Complying with legal obligations (e.g. responding to lawful requests from authorities) | Any data we hold about you | Legal obligation (UU PDP; GDPR Art. 6(1)(c)) |
We do not use your personal data for any purpose beyond those described above. In particular, we do not use contact form data for marketing communications, and we do not sell, rent, or trade your personal data to any third party.
5. How We Share Your Data
We do not sell, trade, or otherwise transfer your personal data to third parties for their own purposes. We may share your data only in the limited circumstances described below.
We use a small number of trusted third-party service providers to help us operate the Website, including website hosting, analytics, and communication tools. These providers are required to process your data only on our instruction and for the specific purposes we have engaged them for. We take reasonable steps to ensure they maintain appropriate technical and organisational security measures and handle your data in accordance with applicable data protection law.
We may disclose your personal data to law enforcement agencies, regulatory bodies, or courts where we are required to do so by applicable law, including in response to a valid legal request. Where legally permitted, we will endeavour to notify you before any such disclosure takes place. Any such cooperation is governed by Section 13 of our Website Terms of Use and does not affect your rights under UU PDP or the GDPR.
In the event of a merger, acquisition, restructuring, or sale of all or part of Impactive’s business or assets, your personal data may be transferred to the acquiring entity. We will ensure that any such transfer is conducted in accordance with applicable data protection law, and that the receiving entity is bound by data protection obligations at least equivalent to those in this Policy.
We do not share your data for marketing purposes, with data brokers, or with any party not described in this section. We do not host third-party advertising on this Website, and no personal data is shared with advertisers.
6. Cookies and Tracking Technologies
This Website uses cookies and similar tracking technologies. Cookies are small text files placed on your device when you visit a website. They allow us to recognise your browser, understand how you use the Website, and improve your experience.
We distinguish between two categories of cookies:
- Strictly necessary cookies: Required for the Website to function. These cannot be disabled. They do not collect personal data that identifies you.
- Optional cookies: Used for analytics, performance measurement, and similar purposes. These are only placed on your device with your explicit consent, obtained through our cookie consent tool.
Full details of the cookies we use, their providers, their purposes, and their lifespans are set out in our Cookie Notice at impactive.id/cookie-notice. You may withdraw your consent to optional cookies at any time through the preference centre accessible in the footer of the Website.
7. How Long We Keep Your Data
We retain your personal data only for as long as necessary for the purposes for which it was collected, and in accordance with our legal obligations. The following retention periods apply:
- Contact form enquiries: Personal data submitted via the contact form (name, email, phone number) is retained for a maximum of 2 (two) years from the date of your enquiry, or until you request deletion, whichever is earlier. This period reflects the typical duration of our business development and follow-up cycle, after which the data is no longer needed for the purpose it was collected.
- Automatically collected data: Technical and analytics data collected through cookies and similar tools is retained in accordance with the lifespan of those tools and the retention periods specified in our Cookie Notice.
- Legal compliance data: Where we are required by law to retain personal data for a longer period (for example, in response to a legal hold or regulatory requirement), we will retain data for that legally mandated period and then securely delete or anonymise it.
Once the applicable retention period has expired, we will securely delete or anonymise your personal data. Where deletion is not immediately possible (for example, because data is stored in backup systems), we will isolate that data from further processing until deletion is completed.
8. Your Data Protection Rights
Depending on your location, you may have the following rights in relation to the personal data we hold about you. These rights are provided under UU PDP for users in Indonesia, and under the GDPR for users in the European Economic Area.
- Right of access: You may request a copy of the personal data we hold about you and information about how we process it.
- Right to rectification: You may request that we correct any inaccurate or incomplete personal data we hold about you.
- Right to erasure: You may request that we delete your personal data, subject to any overriding legal obligations we have to retain it.
- Right to restriction of processing: You may request that we restrict processing of your personal data in certain circumstances, for example while the accuracy of that data is contested.
- Right to withdraw consent: Where we process your personal data on the basis of your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of any processing carried out before withdrawal.
- Right to data portability (GDPR): Where your data is processed by automated means on the basis of consent, you may request that we provide it to you in a structured, commonly used, machine-readable format.
- Right to object (GDPR): You may object to processing of your personal data where we rely on legitimate interests as our legal basis, unless we have compelling legitimate grounds that override your interests.
To exercise any of the above rights, please contact us at info@impactiveagency.com. We will respond to your request within 14 (fourteen) calendar days. We may need to verify your identity before processing your request. We will not charge a fee for handling your request unless it is manifestly unfounded or excessive.
If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the relevant supervisory authority. For users in Indonesia, this is currently the Ministry of Communication and Digital Affairs (Kementerian Komunikasi dan Digital / Komdigi), which oversees UU PDP enforcement. Note that UU PDP also provides for a dedicated Personal Data Protection Commission (Komisi Perlindungan Data Pribadi) to be established; once operational, this body may become the primary supervisory authority for data protection matters. For users in the EU, this is the data protection authority in your country of residence.
9. Data Security
Impactive takes the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your data from unauthorised access, loss, alteration, destruction, or disclosure. These measures include:
- Secure HTTPS encryption for all data transmitted through the Website
- Restricted access controls ensuring that personal data is accessible only to personnel who require it in the course of their work
- Use of reputable, security-vetted third-party service providers for Website hosting and data processing
- Regular review of our security practices to address emerging risks
No method of transmission over the internet or electronic storage is completely secure. While we take all reasonable steps to protect your personal data, we cannot guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority in accordance with our obligations under UU PDP and, where applicable, the GDPR.
10. Links to Third-Party Websites
The Website may contain links to third-party websites. This Privacy Policy applies only to the Website operated by Impactive at impactive.id and its verified subdomains. It does not apply to any third-party website. We encourage you to review the privacy policies of any third-party website you visit before providing personal data to them. We are not responsible for the privacy practices or content of third-party websites.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or other relevant circumstances. We will publish the updated Privacy Policy on this page with a revised effective date. Your continued use of the Website after the revised Policy has been posted constitutes your acknowledgement of the updated terms. We encourage you to review this page periodically.
12. Contact Us
If you have any questions, concerns, or requests in relation to this Privacy Policy or the way we handle your personal data, please contact us at:
Legal and Compliance
Website: impactive.id
Email: info@impactiveagency.com
Phone: +62 821 444 37 232
Address: Jl. Pantai Batu Bolong No.18, Canggu, Bali, Indonesia