隐私政策

Effective Date: 08-Mar-2024

Last Updated: 05-May-2025

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INTRODUCTION

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This Privacy Policy explains how Mulia Group ("Mulia", "us", "our", or "we") collects, uses, discloses, and protects your personal data across our websites, mobile applications, and related services. We are committed to respecting your privacy and safeguarding your information in compliance with the General Data Protection Regulation (GDPR), Indonesia’s PDP Law, and other applicable privacy frameworks globally.

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This policy applies to:

• Our websites and booking platforms;
• Mobile apps and official social media pages;
• Messaging channels including WhatsApp Business, Facebook, Instagram, Website and WeChat;
• Online shopping via Instagram Shop and use of Meta Advertising tools;
• Interactions with our AI-powered concierge chatbots;
• In-person visits and offline communications.

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By using our services, you agree to the terms outlined below. You may also be asked for explicit consent at key moments, such as newsletter sign-ups, bookings, or marketing opt-ins.

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PERSONAL DATA COLLECT

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1. Information You Provide

We collect personal data you voluntarily provide to us, including:

• Full name, date and place of birth, passport/visa details;
• Postal address, email address, and phone number;
• Payment details (credit/debit card number, expiry date, security code);
• Booking history and stay preferences;
• Health or dietary requirements (if necessary for service fulfilment);
• Communication preferences and survey responses;
• Social media account data (Instagram, Facebook, WeChat handles).
• Corporate, wedding, or event-related information submitted through our Request for Proposal (RFP) form, including company or organiser name, event type, and other relevant details for MICE, wedding, or private events planning.

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2. Automatically Collected Data

We also collect certain technical and behavioral data automatically when you visit our Sites:

• IP address, device type, browser version, and location data;
• Pages visited, time spent, referral links;
• Interaction data from our concierge tools and chatbot platforms;
• Tracking data using cookies and related technologies (see below).

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HOW WE USE YOUR INFORMATION

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We use your data for the following purposes:

• Confirming bookings and processing payments;
• Communicating via email, WhatsApp, or WeChat regarding your stay;
• Personalising offers, content, and services based on your preferences;
• Enabling AI-powered concierge tools and guest support;
• Conducting analysis and reporting to improve our services;
• Sending marketing communications (if opted in);
• Complying with legal obligations and ensuring guest safety.

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We may use automated tools and profiling to tailor experiences. You can opt out at any time.

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DISCLOSURE OF INFORMATION

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Your data may be shared with:

• Mulia Group properties and staff as required;
• Booking engines and CRM platforms;
• Advertising partners such as Meta, Google, and TikTok;
• Legal authorities or regulators, when required;
• Third parties during a merger, acquisition, or asset transfer.

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All partners are contractually bound to safeguard your information.

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INTERNATIONAL TRANSFERS

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Your personal data may be processed or stored:

• In Indonesia and the United States;
• By trusted third-party vendors in other jurisdictions.

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We ensure adequate safeguards are in place to protect your data wherever it is transferred.

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LEGAL BASIS FOR PROCESSING

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We rely on the following legal grounds:

• Consent – for marketing, tracking, and data sharing activities;
• Contract – for fulfilling bookings or service requests;
• Legal obligation – to comply with law enforcement or tax regulations;
• Legitimate interest – in delivering relevant services or communications.

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YOUR RIGHTS

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You may exercise the following rights:

• Access and rectify your personal data;
• Request deletion (‘right to be forgotten’);
• Object to processing (including profiling and marketing);
• Withdraw consent at any time;
• File a complaint with a data protection authority.

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To submit a request, contact dataprivacy@themulia.com. You may be asked to provide ID to verify your identity.

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SECURITY MEASURES

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We apply physical, technical, and administrative controls to safeguard your data, including:

• SSL encryption and firewalls;
• Access control based on roles;
• Data minimisation and privacy by design.

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Please ensure your devices and communication channels are secure before sharing data with us.

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DATA RETENTION

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We keep personal information only as long as necessary for:

• Operational, legal, and financial reporting needs;
• Guest services and loyalty program purposes.

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When no longer required, data is anonymised or securely deleted.

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CHILDREN’S PRIVACY

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We do not knowingly collect personal data from individuals under 18 without verified parental or guardian consent. Such data, when required for resort activities or family bookings, is processed with care and only for service fulfilment.

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AUTOMATED PROFILING & AI TOOLS

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We use profiling to personalise services, such as:

• Recognising your past stay preferences;
• Delivering relevant offers;
• Supporting AI chatbots and concierge messaging.

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You may request manual review or opt out of such tools by contacting our Data Privacy team.

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MARKETING COMMUNICATIONS

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You can choose how you receive promotions:

• Opt in during booking, registration, or newsletter sign-up;
• Opt out at any time via email link or by contacting us;
• Manage your preferences through CookieYes and CRM opt-in forms.

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Operational communications (e.g. booking updates) are unaffected by your marketing preferences.

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LINKS TO THIRD-PARTY SITES

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Our websites and content may contain links to third-party sites (e.g. Instagram Shop, event ticketing platforms). We are not responsible for their privacy practices. Please consult their policies before sharing your data.

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CHANGES TO THIS POLICY

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We may update this Privacy Policy periodically to reflect legal or operational changes. The updated version will be posted on our Sites with a revised effective date. For significant updates, we will notify users where appropriate.

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LIMITATION OF LIABILITY

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While Mulia Group takes all reasonable measures to safeguard your personal data, you acknowledge and agree that no data transmission or storage system can be guaranteed to be fully secure. To the extent permitted by law, Mulia Group, its parent company, affiliated entities, officers, directors, employees, agents, and representatives shall not be held liable for any indirect, incidental, consequential, or punitive damages arising from any unauthorised access to, use of, or disclosure of your personal information.

Nothing in this policy shall limit or exclude liability for negligence, fraud, or personal injury resulting from gross misconduct.

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CONTACT US

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For questions, concerns, or data access requests, contact:

Data Protection Officer

E: dataprivacy@themulia.com

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Please include:

• Your full name;
• Contact details;
• Your request and supporting ID documentation.

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You may also raise concerns with the relevant data protection authority in your jurisdiction.