PRIVACY POLICY

Effective Date: [1 January 2026]

PT CBD REALTY INDONESIA (“PT CBD Realty Indonesia”, “we”, “our”, or “us”) respects your privacy and is committed to protecting the personal information you provide when visiting and using www.elements-apartment.com (the “Website”).

This Privacy Policy explains how we collect, use, store, disclose, and protect personal information obtained through the Website and through communications initiated through the Website.

The Website is operated as an information and property marketing website for The Elements Apartment. It is intended to provide information about the property, facilities, available units, sales and leasing opportunities, and to facilitate communication between prospective buyers, tenants, property owners, and our sales or leasing representatives.

The Website is not an online marketplace or payment platform, and it does not process or hold property purchase payments through the Website.

1. INFORMATION WE COLLECT

We may collect personal information when you voluntarily provide it to us through the Website or when you communicate with us regarding The Elements.

Depending on how you interact with the Website, the information we may collect includes:

a. Contact Information

This may include:

• Full name;

• Telephone or mobile number;

• Email address;

• Preferred method of communication; and

• Other contact details that you voluntarily provide.

b. Property Enquiry Information

When you request information about The Elements, we may collect information relating to your enquiry, such as:

• Type of property or unit you are interested in;

• Preferred unit type;

• Purchase or rental interest;

• Preferred viewing date or appointment;

• Budget range, if voluntarily provided;

• Intended use of the property; and

• Other information you choose to provide in connection with your property enquiry.

c. Communications

If you contact us by telephone, WhatsApp, email, contact form, or other communication channels made available through the Website, we may retain information relating to the communication for purposes of responding to your enquiry, providing customer service, coordinating property viewings, and maintaining appropriate business records.

d. Website Usage Information

When you visit the Website, certain technical information may be collected automatically, including:

• IP address;

• Browser type;

• Device type;

• Operating system;

• Pages visited;

• Date and time of access;

• Referring website; and

• General information about how you interact with the Website.

This information may be collected through cookies, analytics tools, server logs, or similar technologies.

2. HOW WE USE YOUR INFORMATION

We may use personal information collected through the Website for the following purposes:

a. Responding to Enquiries

To respond to requests for information regarding The Elements, including unit availability, specifications, facilities, pricing information, sales, leasing, and viewing appointments.

b. Property Marketing and Sales

To assist prospective buyers with their property enquiries, unit selection, sales discussions, negotiations, and other activities related to a potential property transaction.

c. Leasing Services

Where you express an interest in renting a unit, we may use your information to facilitate communication regarding availability, rental terms, viewing appointments, and leasing arrangements.

d. Communication

To contact you regarding your enquiry, appointment, property information, transaction-related matters, or other communications that you have requested.

e. Customer Service

To provide customer support and maintain appropriate records relating to your enquiries and interactions with us.

f. Website Improvement

To understand how visitors use the Website, identify technical issues, improve the Website, and improve the information and services we provide.

g. Marketing Communications

Where permitted by applicable law and, where required, with your consent, we may use your contact information to provide information about The Elements, property opportunities, services, promotions, or other real estate-related information that may be relevant to you.

You may request to stop receiving marketing communications from us at any time.

h. Legal and Compliance Purposes

We may process personal information where necessary to comply with applicable laws, regulations, legal processes, or legitimate requests from competent authorities.

3. PROPERTY TRANSACTION AND PAYMENT INFORMATION

The Website does not operate as an online property marketplace and does not process property purchase payments through the Website.

If you decide to purchase or rent a property after communicating with us, the relevant transaction will be subject to the applicable terms, documentation, and procedures provided by the property developer, seller, owner, or other authorized transaction party.

For property purchases, PT CBD Realty Indonesia acts as a property agent/marketing representative and does not receive or hold the purchase funds on behalf of the property developer or seller, unless otherwise expressly agreed in writing.

Any property purchase payment should be made directly to the officially designated account of the developer/seller or other authorized payment entity, in accordance with the applicable transaction documentation.

PT CBD Realty Indonesia does not request prospective buyers to transfer property purchase funds to an account belonging to PT CBD Realty Indonesia unless expressly stated in an official written agreement.

4. SHARING OF PERSONAL INFORMATION

We may share your personal information only where reasonably necessary for the purposes described in this Privacy Policy or where otherwise permitted or required by applicable law.

Depending on the circumstances, information may be shared with:

a. Property Developer, Seller, or Owner

Where necessary to respond to your enquiry, arrange a viewing, provide requested property information, or facilitate a potential sales or leasing transaction.

b. Authorized Property Representatives

Information may be shared with authorized representatives involved in the sales, leasing, administration, or transaction process for the relevant property.

c. Service Providers

We may use third-party service providers to support the operation of our Website and business, such as:

• Website hosting providers;

• Website maintenance providers;

• Analytics providers;

• Communication or email service providers;

• Customer relationship management systems; and

• Other technology or professional service providers.

These providers may process personal information only to the extent reasonably necessary to provide their services.

d. Legal and Regulatory Authorities

We may disclose personal information where required by applicable law, regulation, court order, governmental request, or other lawful process.

5. WE DO NOT SELL YOUR PROPERTY PURCHASE THROUGH THIS WEBSITE

The Website is intended to provide information and facilitate property enquiries.

We do not sell “listings” through the Website, and users are not purchasing a listing from the Website.

Any reference to a property price, promotional offer, unit availability, or other commercial information is provided for property marketing and enquiry purposes and may be subject to change or confirmation by the relevant authorized party.

6. COOKIES AND ANALYTICS

The Website may use cookies and similar technologies to:

• Ensure the Website functions properly;

• Remember certain preferences;

• Understand Website traffic and usage;

• Improve Website performance and user experience; and

• Measure the effectiveness of marketing activities.

You may adjust your browser settings to block or delete cookies. However, certain Website functionality may be affected if cookies are disabled.

Where third-party analytics or marketing technologies are used, their processing of information may also be subject to their respective privacy policies.

7. MARKETING COMMUNICATIONS

If you provide your contact information through the Website, we may contact you regarding your property enquiry or related services.

Where permitted by applicable law, we may also send information about:

• The Elements;

• Property availability;

• Sales opportunities;

• Leasing opportunities;

• Property-related services;

• Promotional information; and

• Other real estate-related information.

You may opt out of marketing communications at any time by contacting us or using the unsubscribe mechanism provided in the relevant communication.

8. DATA SECURITY

We take reasonable measures to protect personal information against unauthorized access, alteration, disclosure, loss, or misuse.

However, no method of transmission or storage over the Internet can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to protect personal information, we cannot guarantee absolute security of information transmitted through the Internet.

9. DATA RETENTION

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to:

• Respond to enquiries;

• Provide requested services;

• Manage business and property-related relationships;

• Maintain appropriate transaction or communication records;

• Comply with legal and regulatory obligations;

• Resolve disputes; and

• Protect our legal rights and interests.

The retention period may vary depending on the nature of the information and the purpose for which it is processed.

10. YOUR PRIVACY RIGHTS

Subject to applicable laws and regulations, you may have rights in relation to your personal information, including rights to:

• Obtain information regarding the processing of your personal data;

• Access your personal information;

• Correct or update inaccurate personal information;

• Request deletion of personal information where permitted by applicable law;

• Withdraw consent where processing is based on consent;

• Request restriction of certain processing activities where applicable; and

• Submit a complaint or request relating to the processing of your personal information.

These rights are subject to applicable legal requirements and limitations.

Indonesia's Law No. 27 of 2022 on Personal Data Protection (UU Pelindungan Data Pribadi) establishes rights for personal data subjects and regulates the processing and protection of personal data.

To exercise applicable privacy rights or submit a privacy-related enquiry, please contact us using the contact details provided below.

11. THIRD-PARTY WEBSITES AND SERVICES

The Website may contain links to websites or services operated by third parties.

We are not responsible for the privacy practices, content, or security of third-party websites or services.

We recommend reviewing the privacy policies of third-party websites before providing personal information to them.

12. CHILDREN'S PRIVACY

The Website is intended for a general audience and is not specifically directed at children.

We do not knowingly seek to collect personal information from children where such collection is prohibited by applicable law.

If you believe that a child has provided personal information to us without appropriate authorization, please contact us so that we can take appropriate steps.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our business practices, Website functionality, applicable laws, or privacy practices.

Any updated Privacy Policy will be published on this Website together with the applicable effective date.

We encourage you to review this Privacy Policy periodically.

14. CONTACT US

If you have questions about this Privacy Policy, our processing of personal information, or wish to exercise applicable privacy rights, please contact:

PT CBD REALTY INDONESIA
TCC Batavia Tower One
Jl. KH Mas Mansyur Kav. 126
Jakarta, Indonesia

Website: www.elements-apartment.com
Email: [INSERT OFFICIAL PRIVACY / COMPANY EMAIL]
Telephone / WhatsApp: [INSERT OFFICIAL NUMBER]

Catatan penting dari saya

Saya sengaja tidak memasukkan beberapa bagian dari privacy policy lama karena tidak konsisten dengan model website Anda, antara lain:

• “If you purchase a listing…” → dihapus.

• Rent Group → dihapus.

• Apartment Guide / mobile applications → dihapus karena dokumen tidak menunjukkan bahwa PT CBD Realty Indonesia memiliki aplikasi tersebut. Dokumen lama memang menyebut “Apartment Guide and Rent. mobile applications”.

• User account → dihapus.

• Rental application / credit score / background check → dihapus karena tidak sesuai dengan fungsi website yang Anda jelaskan.

• Property reviews → dihapus.

• “Schedule a tour” sebagai fitur platform → saya ubah menjadi proses enquiry/appointment, sehingga tidak mengesankan website mempunyai sistem marketplace sendiri.

• Payment processor → dihapus dari konteks website. Ini penting karena sebelumnya Anda sudah menjelaskan bahwa pembayaran pembelian properti dilakukan langsung kepada pihak yang ditunjuk, bukan kepada PT CBD Realty Indonesia.

• “Rent Group does not disclose…” → dihapus karena jelas merupakan sisa template pihak lain. Dokumen lama masih menggunakan nama Rent Group pada bagian disclosure.

• California-specific privacy provisions → sebaiknya tidak ditempel begitu saja apabila target utama website adalah pasar Indonesia. Dokumen lama bahkan memasukkan kategori California Customer Records dan konsep “sale/share” personal information.

Dengan struktur baru ini, posisi website menjadi konsisten: