Privacy Policy

This Privacy Policy explains how PT Aussie Core Builders ("we", "us") handles personal data collected through the marketing website solbyicg.com (the "Site"). The Site does not sell securities, take payments, or operate any user account; its sole purpose is to inform prospective buyers about the SOL Nusa Dua villa development and to forward inquiries to our sales team.

Who we are

We act as the data controller for personal data submitted through the Site.

What data we collect

We collect only what we need to answer inquiries and run the Site. Specifically:

• Contact-form submissions. Name and phone are required. Email, investment amount, timeframe, message, and (when you ask about a specific villa from the gallery) villa type, price, and area are optional. A hidden honeypot field and the timestamp at which the form was rendered are also captured solely to detect automated submissions.
• Local browser storage. Your language preference (`language`) and your cookie-consent choice (`sol-consent-v1`). These are stored in your browser only and never sent to us.
• Server logs. Standard hosting logs (IP address, user-agent, timestamp, requested path) are processed by our hosting provider Vercel for operational and security purposes.
• Analytics — only with your consent. If you opt in to analytics, Google Analytics 4 (with IP-anonymisation enabled) and Vercel Analytics / Speed Insights are loaded. They collect page views, referrer, approximate location derived from IP, device and browser characteristics, and Web Vitals. None of this loads before you consent.
• Marketing — only with your consent. We do not currently run any advertising or remarketing pixels. The marketing category is reserved for future campaigns and remains off by default.

Why we use it and our legal bases (GDPR Art. 6)

• Responding to inquiries, scheduling consultations, and preparing offers — pre-contractual measures and our legitimate interest in running a sales process (Art. 6(1)(b) and (f)).
• Detecting automated/spam submissions via the honeypot and timing fields — legitimate interest in protecting the Site (Art. 6(1)(f)).
• Operating, securing, and debugging the Site (server logs) — legitimate interest (Art. 6(1)(f)).
• Analytics — your consent (Art. 6(1)(a)).
• Future marketing communications — your consent (Art. 6(1)(a)).

Cookies and similar technologies

We use the minimum tracking required, organised into three categories:

• Strictly necessary. Stores your language preference and your consent choice in localStorage. Always on; cannot be disabled because the Site cannot function without them.
• Analytics (opt-in). Google Analytics sets `_ga` and `_ga_<container>` cookies and reports events to Google. Vercel Analytics and Speed Insights use cookieless beacons. Loaded only after you click "Accept all" or enable Analytics in Customize.
• Marketing (opt-in). Reserved for advertising and remarketing pixels (e.g. Google Ads, Meta) when we run paid campaigns. Off today.

Manage your preferences

You can change or withdraw your consent at any time below. Changes take effect immediately.

Third parties we share data with

We rely on a small number of processors. We share only what each processor needs.

• Telegram FZ-LLC (UAE). Inquiry forwarding. When you submit the contact form, the message is delivered to a private Telegram chat we monitor. Telegram processes the message under its own privacy policy.
• Vercel Inc. (USA / EU edge). Hosting, content delivery, server logs, and (with your consent) Vercel Analytics and Speed Insights.
• Google LLC / Google Ireland Limited. Google Analytics (with your consent only). For visitors in the EU/EEA, Google Ireland is the data importer.

International transfers

Personal data may be transferred to Indonesia (where we are established), the United States (Telegram, Google, Vercel infrastructure), and the European Union (Vercel EU edge). For transfers from the EU/EEA, UK, or Switzerland to recipients in countries without an adequacy decision, we rely on the European Commission's Standard Contractual Clauses (SCC) and apply data minimisation.

How long we keep data

• Inquiry messages forwarded to Telegram remain in the Telegram chat history for up to 24 months from the date of contact, unless a longer period is required for an active sales process or by law.
• Hosting and security logs follow Vercel's retention.
• Analytics data is retained per the Google Analytics retention setting we have configured (default 14 months) and Vercel's policies.
• After these periods data is deleted or anonymised.

Your rights

Depending on where you live, you have some or all of the following rights:

• Access — request a copy of your data.
• Rectification — correct inaccurate data.
• Erasure ("right to be forgotten") — ask us to delete your data.
• Restriction — limit how we use your data.
• Data portability — receive your data in a portable format.
• Objection — object to processing based on legitimate interests.
• Withdraw consent at any time, where processing is based on consent (this does not affect the lawfulness of processing before withdrawal).
• Lodge a complaint with your supervisory authority (e.g. your EU member-state DPA, the OAIC in Australia, or Kominfo in Indonesia).

California residents have additional rights under the CCPA/CPRA, including the right to know what we collect, to delete it, and to opt out of any "sale" or "sharing". We do not currently sell or share personal information for cross-context behavioural advertising; if that ever changes, a "Do Not Sell or Share My Personal Information" link will appear on the Site.

How to exercise your rights

Email info@solbyicg.com from the address you used to contact us, or call +62 813 3704 3467. We aim to respond within 30 days.

Security

All traffic is served over HTTPS. The contact form is validated server-side, protected by an origin allow-list, a hidden honeypot, and a minimum-fill-time check. We apply security headers (CSP, HSTS, Permissions-Policy, COOP/CORP) and minimise the data we collect. No method of transmission or storage is 100% secure; we cannot guarantee absolute security.

The Site is intended for an adult audience. We do not knowingly collect data from persons under 18.

Changes to this Policy

We may update this Policy as the Site or applicable law changes. The current version date is shown at the top. Material changes will be flagged on the Site.

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