Privacy Policy User Agreement

Privacy Policy User Agreement Template for Indonesia

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Key Requirements PROMPT example:

"I need a Privacy Policy User Agreement for my Indonesian e-commerce platform launching in March 2025, which will process customer data across Southeast Asia and needs to comply with Indonesian PDP Law while including provisions for international data transfers."

Document background

The Privacy Policy User Agreement is a fundamental document required for any organization operating in Indonesia that collects, processes, or stores personal data. This document has become increasingly critical following the implementation of Law No. 27 of 2022 on Personal Data Protection (PDP Law), which introduced strict requirements for personal data handling. The agreement serves dual purposes: informing users about their data privacy rights and establishing the legal relationship between the service provider and users regarding data processing activities. It must address specific requirements under Indonesian law, including explicit consent mechanisms, data subject rights, data localization requirements, and mandatory security measures. Organizations should implement this document before collecting any personal data and update it regularly to reflect changes in operations or regulations.

Suggested Sections

1. Parties: Identification of the service provider and definition of user/data subject

2. Background: Context of the agreement and purpose of the privacy policy

3. Definitions: Key terms used throughout the policy, including technical terms and legal definitions aligned with Indonesian PDP Law

4. Scope and Application: Details of what the privacy policy covers and to whom it applies

5. Consent and Legal Basis: How user consent is obtained and other legal bases for data processing

6. Personal Data Collection: Types of personal data collected and methods of collection

7. Use of Personal Data: Purposes and legal basis for processing personal data

8. Data Storage and Security: How personal data is stored, protected, and security measures implemented

9. Data Sharing and Disclosure: Third parties with whom data is shared and circumstances of disclosure

10. User Rights: Rights of users under Indonesian law including access, correction, and deletion

11. Data Retention: Period for which personal data is retained and criteria for retention

12. Changes to Privacy Policy: Process for updating the privacy policy and notifying users

13. Contact Information: How users can contact the company regarding privacy concerns

14. Governing Law: Specification of Indonesian law as governing law and jurisdiction

Optional Sections

1. International Data Transfers: Required if personal data is transferred outside Indonesia

2. Children's Privacy: Required if services may be accessed by children under 17

3. Cookies and Tracking: Required for websites and apps using cookies or similar technologies

4. Social Media Integration: Required if the service integrates with social media platforms

5. Special Categories of Data: Required if processing sensitive personal data as defined in PDP Law

6. Direct Marketing: Required if personal data is used for marketing purposes

7. Automated Decision Making: Required if using automated processing to make decisions about users

8. Data Breach Procedures: Optional but recommended section detailing response to data breaches

Suggested Schedules

1. Schedule 1 - Types of Personal Data: Detailed list of all personal data collected and processed

2. Schedule 2 - Technical and Security Measures: Detailed description of security measures and protocols

3. Schedule 3 - Third Party Processors: List of approved third-party data processors and their roles

4. Schedule 4 - Cookie Policy: Detailed information about cookies and tracking technologies used

5. Appendix A - Data Subject Request Form: Template form for users to exercise their data rights

6. Appendix B - Consent Withdrawal Form: Template form for withdrawing previously given consent

Authors

Alex Denne

Head of Growth (Open Source Law) @ tiktok��˰� | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co

Relevant legal definitions

Clauses

Relevant Industries

Technology

E-commerce

Financial Services

Healthcare

Education

Retail

Telecommunications

Social Media

Digital Services

Professional Services

Travel and Hospitality

Entertainment

Banking

Insurance

Media and Publishing

Relevant Teams

Legal

Compliance

Information Technology

Information Security

Risk Management

Data Protection

Privacy

Operations

Customer Service

Digital Operations

Product Development

User Experience

Marketing

Human Resources

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Chief Legal Officer

Privacy Counsel

Compliance Manager

Information Security Manager

Chief Technology Officer

Chief Information Officer

Risk Manager

Legal Counsel

Privacy Manager

Compliance Officer

IT Security Manager

Chief Operating Officer

Digital Operations Manager

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