Pantograf Portal & Application

PANTOGRAF PRIVACY POLICY

Provider: PT Pemeta Antariksa Grafika | Document Version: 2.0 | Effective Date: 3 August 2026

This Privacy Policy explains how PT Pemeta Antariksa Grafika processes personal data in connection with the Pantograf Portal and Application. This Policy is an inseparable part of the Pantograf Terms and Conditions of Use.

The binding text is the Indonesian text. Translations into other languages, if provided, are for ease of understanding only.

Capitalized terms not defined in this Policy - including Platform, Portal, Application, Service, Account, User Data, Subscription Period, Voucher, Aggregated and Anonymized Data, Calendar Day, Business Day, and Child - have the meanings set out in the Pantograf Terms and Conditions of Use - Individual Service.

Section 1 - Who We Are

(1) The Personal Data Controller for processing described in Section 2(1) is PT Pemeta Antariksa Grafika (“Pantograf”, the “Provider”, or “We”), a limited liability company established under the laws of the Republic of Indonesia, domiciled at Jl. BDN 1, Kelurahan Cilandak Barat, Kecamatan Cilandak, Kota Administrasi Jakarta Selatan, DKI Jakarta 12430, with Business Identification Number (NIB) 1405260002939.

(2) Questions, requests to exercise rights, and complaints regarding personal data are sent via email contact@pantograf.app or the Portal complaints channel.

(3) We process personal data in accordance with the laws and regulations of the Republic of Indonesia, including Law of the Republic of Indonesia Number 27 of 2022 on Personal Data Protection (UU PDP) and its implementing regulations.

Section 2 - Scope and Our Role

(1) We act as Personal Data Controller for personal data processed through the Portal, namely Account data, billing and payment data, security data, and usage data as described in Section 3. For this data, all Controller obligations in this Policy apply directly to Us, without an intermediary.

(2) We act as Personal Data Processor for other persons’ personal data contained in materials You Yourself upload into the Application - including spatial files, documents, and certificates containing names, addresses, identity numbers, or other persons’ personal data. For that data, You are the Controller, and You must ensure a lawful basis for processing before uploading it.

(3) For business and institutional clients, the parties’ roles are set out in a separate document and may differ from this Policy.

(4) This Policy applies to individual Account holders, Application users, and visitors to Portal pages.

Section 3 - Personal Data We Process

(1) Account Data: email address, username, display name, account image (optional), password hash (We do not store passwords in readable form), role, email verification status, and Account status.

(2) Google Sign-In Data: if You choose to sign in with Google, We receive an identity token and identifiers provided by Google for authentication, typically email address and Google account identifier. We use this data solely to authenticate and manage Your Account.

(3) Security Data: multi-factor authentication secrets and status, session cookies, and technical data processed by anti-robot (captcha) verification services at registration.

(4) Usage Data: approximate country or region derived from IP address, last visit time, and similar operational metadata, for security, display localization, and service integrity.

(5) Billing and Commercial Data: selected package, subscription period, Voucher use, payment references, and transactional emails such as receipts and renewal reminders.

(6) Support and Communications Data: messages You send to Us and transactional emails We send to You.

(7) Materials You Upload to the Application: spatial or GIS files, documents, certificates, and other content together with personal data contained therein - processed on Your behalf as in Section 2(2).

(8) Aggregated and Anonymized Data: statistical and technical data on system performance, features used, and error logs, processed so it cannot be used to identify You or Your projects. We do not treat the contents of Your maps, spatial files, documents, or certificates as part of this data.

Section 4 - Purposes and Bases for Processing

(1) We process personal data on the following bases:

(2) We do not sell Your personal data.

(3) We do not currently make decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant effects for You.

Section 5 - Data from Google Sign-In

(1) Our use of information received from Google APIs is subject to the Google API Services User Data Policy, including Limited Use requirements.

(2) We do not use Google data for advertising and do not sell it.

Section 6 - Processing and Retention Periods

(1) Materials You upload to the Application are stored during the Subscription Period. After the Account is closed or the Subscription Period ends without renewal, You are given 30 (thirty) Calendar Days to download them, after which We delete them from active systems and from backups according to the backup cycle, no later than 90 (ninety) Calendar Days.

(2) Account Data and Billing Data are stored while the Account is active and, after the Account is closed, for 5 (five) years from the date You last were a user, to meet personal-data retention obligations for Electronic Systems and tax and bookkeeping obligations. After that period, data is deleted or destroyed.

(3) During the period in paragraph (2), data is stored in limited form and used for those retention purposes, including meeting legal obligations, defending or enforcing rights in disputes, and responding to lawful requests from authorities.

(4) If You request deletion while a legal retention obligation applies, We stop processing and restrict access to that data, then delete it when the retention obligation ends. We explain this to You.

(5) Aggregated and Anonymized Data may be retained indefinitely because it cannot be used to identify You.

(6) Records of consent to the Terms and Conditions - time, date, Account identity, and document version - are kept while the Account is active and for 5 (five) years thereafter as an audit trail.

Section 7 - Sharing and Sub-Processors

(1) We may share personal data with:

a. infrastructure and storage providers used to run the Portal and Application and backups, including Cloudflare R2 object storage;

b. email delivery providers for transactional email;

b.1. anti-robot (captcha) verification providers used on registration forms to prevent abuse;

c. payment service providers when You make a payment;

d. Google, solely as part of Google Sign-In if You choose that method;

e. law enforcement or competent authorities, insofar as required by law or a lawful request; and

f. professional advisers bound by confidentiality, insofar as necessary.

(2) We bind each sub-processor to data-protection obligations equivalent to this Policy.

(3) The list of sub-processors and processing locations is published as an annex to this Policy accessible through the Portal. We notify changes before they take effect.

(4) We do not share Your personal data with others for third-party marketing without Your consent.

Section 8 - Processing Outside Indonesia

(1) Personal data may be processed on servers or by sub-processors located outside the territory of the Republic of Indonesia.

(2) We make such transfers only where: the recipient’s country has an equal or higher level of personal-data protection; or there is adequate and binding personal-data protection; or based on Your consent - in accordance with Article 56 of Law Number 27 of 2022.

(3) As a Private-Scope Electronic System Operator (Penyelenggara Sistem Elektronik Lingkup Privat), We ensure the effectiveness of oversight by the relevant Ministry or Agency and law enforcement over the Electronic Systems and Electronic Data We manage, including data processed outside Indonesia.

Section 9 - Security and Encryption

(1) We apply reasonable technical and organizational measures to protect personal data, including access controls, least-privilege personnel access, and operational monitoring.

(2) Personal data We store in Electronic Systems is stored in encrypted form, in accordance with legal obligations on personal-data protection in electronic systems.

(3) Under the Terms and Conditions, Our personnel do not open, read, or access the contents of materials You upload to the Application on the Individual Service, except in three limited cases: at Your express request; insofar as strictly necessary to address a disruption, security incident, or system emergency that cannot be resolved without such access, limited to minimum scope and duration; or under a lawful request from law enforcement or a court. We log every such access, You may request the log, and We notify You insofar as not prohibited by law.

(4) Paragraph (3) addresses access by a person. Automatic system processing as needed to operate the Service - including storage, display, processing, and backup - is not access under paragraph (3).

(5) No system is completely secure. You help protect security by keeping credentials confidential and enabling multi-factor authentication when available.

Section 10 - Notice of Personal Data Protection Failures

(1) If a personal-data protection failure occurs for personal data of which We are Controller under Section 2(1), We give written notice no later than 3 × 24 (three times twenty-four) hours to You as data subject and to the competent authority.

(2) Notice includes at least: the personal data disclosed; when and how it was disclosed; and remediation and recovery measures We take.

(3) If a failure occurs for personal data of which You are Controller under Section 2(2), We notify You no later than 1 × 24 (one times twenty-four) hours after We learn of it, with reasonably available information so You can meet Your own notice obligations, and We provide reasonable cooperation.

(4) In certain cases We also announce the failure to the public.

Section 11 - Your Rights over Personal Data

(1) For personal data of which We are Controller, You have the right to:

a. obtain information on the clarity of identity, legal interest basis, purpose of request and use of personal data, and accountability of the requesting party;

b. complete, update, and/or correct errors or inaccuracies in Your personal data;

c. obtain access to and copies of Your personal data;

d. end processing, erase, and/or destroy Your personal data;

e. withdraw consent You have given;

f. object to decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant effects for You;

g. delay or restrict processing of Your personal data;

h. sue and receive compensation for violations of processing of Your personal data; and

i. obtain and use Your personal data in a commonly used or machine-readable format, and transmit it to another Personal Data Controller insofar as the systems can communicate securely.

(2) Requests to exercise rights are submitted in a recorded manner through the channel in Section 1(2). We may request identity verification before fulfilling a request.

(3) We respond to requests no later than 30 (thirty) Calendar Days. If a request needs further examination, We notify the reason and estimated completion time.

(4) Exercise of rights may be limited insofar as permitted by laws and regulations, including for law enforcement or retention obligations under Section 6.

(5) For personal data of which You are Controller under Section 2(2), requests from the relevant data subject are directed to You; We assist You as Processor.

Section 12 - Cookies and Similar Technologies

(1) The Portal uses essential cookies and local session mechanisms, including HTTP-only session cookies, to keep You signed in and secure authentication.

(2) We do not use those essential cookies for third-party advertising.

Section 13 - Children and Age Limits

(1) The minimum age to use the Service is 18 (eighteen) years. The Service is not designed, intended, or marketed for use or access by a Child, meaning a person under 18 years of age.

(2) We provide an age-verification mechanism at registration and do not knowingly process a Child’s personal data.

(3) Processing of a Child’s personal data, if it occurs, may only be done with parent or guardian consent in accordance with laws and regulations.

(4) If We learn an Account was registered by a Child, We deactivate that Account and delete related personal data, unless consent under paragraph (3) is obtained.

(5) We provide a reporting mechanism for anyone who finds suspected use of the Service by a Child or suspected violation of a Child’s rights, through the channel in Section 1(2).

Section 14 - Changes to the Privacy Policy

(1) We may update this Privacy Policy from time to time.

(2) Changes to personal-data processing information are notified to You in advance, before they take effect, by email and/or the Portal.

(3) We state the effective date on each version and retain prior versions so You can access them.

(4) Changes to this Policy do not reduce Your rights under laws and regulations or under the Terms and Conditions applicable to a running Subscription Period.

Section 15 - Complaints and Dispute Resolution

(1) Complaints about personal-data processing are first submitted to Us through the channel in Section 1(2). We give an initial response no later than 3 (three) Business Days and resolve the complaint no later than 30 (thirty) Calendar Days.

(2) If a complaint is not resolved, You may submit a complaint to the ministry responsible for communications and digital affairs, and to the competent personal-data protection authority under laws and regulations then in force.

(3) You retain the right to pursue dispute resolution as provided in the Terms and Conditions and laws and regulations, including consumer protection.

Section 16 - Related Documents

(1) Use of the Individual Service is also subject to the Pantograf Terms and Conditions of Use - Individual Service.

(2) For business and institutional clients, separate documents apply, which may set different Controller and Processor roles.

Section 17 - Contact

Questions, requests to exercise rights, and complaints regarding personal data: PT Pemeta Antariksa Grafika, Jl. BDN 1, Kelurahan Cilandak Barat, Kecamatan Cilandak, Kota Administrasi Jakarta Selatan, DKI Jakarta 12430 - email contact@pantograf.app.

Annex - Sub-Processor List

This list is the annex to the Privacy Policy under Section 7(3). Changes will be notified before they take effect.