Privacy Policy

1. Who We Are

This website is operated by PT Tropical Estate Solution, operating under the commercial brand Sumbawa Property Trust or SPT.

PT Tropical Estate Solution
Email: hello@sumbawa-trust.com

For the purposes of this Privacy Notice, “we”, “us”, and “our” mean PT Tropical Estate Solution.

2. Scope of This Notice

This Privacy Notice explains how we collect, use, store, disclose, and protect personal data submitted through this website, email, WhatsApp, online forms, property enquiries, consultations, and related communications.

SPT provides commercial property-consulting, marketing, introduction, and transaction-coordination services. We are not a notary, PPAT, legal adviser, bank, escrow agent, or title holder unless expressly stated in a separate written agreement.

Landowners, sellers, buyers, notaries, PPATs, lawyers, banks, tax advisers, government bodies, and other transaction participants process personal data under their own policies and legal obligations.

3. Personal Data We May Collect

We may collect:

• name;
• email address;
• WhatsApp number or other contact details;
• investor type, budget range, land requirements, preferred location, intended use, and timing;
• messages, enquiries, files, and communications you send to us;
• technical information, including IP address, browser type, device information, referral source, pages viewed, cookie preferences, and interaction data;
• information voluntarily provided during a consultation, site visit, or transaction enquiry.

4. Why We Use Personal Data

We may use personal data to:

• respond to enquiries;
• provide requested property information, maps, videos, brochures, or market materials;
• arrange calls, consultations, site visits, and introductions;
• assess whether an enquiry may match a property opportunity;
• coordinate requested communications with relevant transaction participants;
• maintain records of enquiries, communications, and consent;
• operate, secure, maintain, and improve the website;
• prevent fraud, misuse, unauthorised access, or security incidents;
• comply with legal, tax, accounting, or record-keeping obligations;
• send market updates or property opportunities where you have separately opted in.

We do not require consent to marketing as a condition of responding to an enquiry.

5. Basis for Processing

Where applicable law requires a legal basis, we process personal data based on one or more of the following:

• your consent;
• your request for information or pre-contractual steps;
• our legitimate interests in operating the website, responding to enquiries, and protecting our business;
• compliance with legal obligations;
• the establishment, exercise, or defence of legal claims.

6. Who May Receive Personal Data

Access to personal data is limited to authorised personnel and service providers who need it for legitimate business purposes.

We may use providers for:

• website hosting and technical support;
• email and messaging tools;
• cloud storage and document management;
• website security;
• analytics and advertising measurement;
• accounting, legal, tax, and technical support.

Where necessary for a service you request, we may share relevant information with a landowner, seller, notary, PPAT, lawyer, tax adviser, surveyor, bank, or other transaction participant.

We do not sell, rent, or trade personal data.

We do not disclose your contact details to landowners or other third parties for their independent marketing purposes.

7. WhatsApp and Marketing Communications

If you provide a WhatsApp number, we may contact you by WhatsApp regarding your specific enquiry, requested information, consultation, or transaction coordination.

Marketing communications by email or WhatsApp will be sent only where you have separately opted in or where otherwise permitted by applicable law.

You may unsubscribe from marketing communications at any time by using the unsubscribe link, replying “STOP”, or contacting hello@sumbawa-trust.com.

8. Cookies

This website uses only strictly necessary cookies required for it to function, such as cookies for page delivery, form submission, and security. We do not use analytics or advertising cookies, and we do not use Google Analytics, Google Tag Manager, or Google Ads tracking on this website. If we introduce analytics or advertising technologies in the future, we will update this Notice and our Cookie Policy and, where required, obtain your consent through a cookie banner before any non-essential cookies are set. Further details are set out in our Cookie Policy.

10. International Transfers

Some of our service providers, such as website hosting, email, and cloud storage, may process personal data outside Indonesia, including in the European Union. Where personal data is transferred to a country that does not provide an equivalent level of protection, we rely on appropriate safeguards, such as Standard Contractual Clauses or another lawful transfer mechanism, and take measures appropriate to the nature of the transfer and applicable law. Further information is available on request.

11. Data Retention

We retain:

• general enquiries for up to 24 months after the last meaningful interaction;
• marketing-consent records for as long as needed to demonstrate consent or honour an opt-out;
• transaction, legal, tax, and accounting records for the period required by law or the relevant written agreement;
• technical and cookie data for the periods described in our Cookie Policy.

We may retain data for longer where necessary to establish, exercise, or defend legal claims.

12. Your Rights

Subject to applicable law, you may request to:

• access personal data we hold about you;
• correct inaccurate or incomplete data;
• withdraw consent;
• object to certain processing;
• request deletion or restriction of processing;
• obtain information about how your data is used;
• stop receiving marketing communications;
• obtain a copy of certain data in a portable format (data portability);
• lodge a complaint with a competent data protection supervisory authority.

To submit a request, contact: hello@sumbawa-trust.com

We may request reasonable information to verify your identity before responding.

13. Security

We use reasonable organisational and technical measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure.

No internet-based system is completely secure. You should avoid sending highly sensitive information through unsecured channels.

14. Changes to This Notice

We may update this Privacy Notice where our website, services, providers, or legal obligations change.

The current version will always be published on this website with an updated “Last updated” date.

15. Children’s Data

This website is intended for adult investors and professional counterparties. We do not knowingly collect personal data from children. If you believe a child has provided personal data, contact hello@sumbawa-trust.com and we will take appropriate steps to delete it.

16. Contact

PT Tropical Estate Solution
Email: hello@sumbawa-trust.com