Scope

This policy applies to surplusadvisory.id (the “Site”), operated by Surplus Indonesia Advisory, known as SUR+ Advisory Indonesia (“SUR+”, “we”). We process personal data in accordance with Indonesia’s Law No. 27 of 2022 on Personal Data Protection and its implementing regulations.

This policy does not cover data we receive in the course of advisory engagements with clients, which is governed by the respective engagement agreements.

Data we collect

We only collect data you give us directly, or that the Site needs to run securely:

  • Contact form: your name, email address, message, page language, time of submission, and IP address (used only to detect spam).
  • Article comments: the name you enter, your email address, your comment, language, and time of submission. Every comment is reviewed first; once approved, your name and comment are shown publicly on the article page. Your email address is only visible to moderators and is never published.
  • Technical data: standard server logs (IP address, browser type, requested page, and time of access) for security and maintenance.

We do not ask for specific (sensitive) personal data such as health, biometric, or financial data through the Site. Please do not include it in messages or comments.

Purposes and legal basis

  • Responding to enquiries you send through the contact form, based on the consent you give when you submit it.
  • Displaying and moderating comments on Insight articles, based on the consent you give when you post them.
  • Keeping the Site secure and preventing spam and abuse, based on our legitimate interests.
  • Complying with applicable legal obligations.

We do not sell, rent, or trade your personal data, and we do not use it for advertising.

Cookies and browser storage

The public Site does not use tracking cookies, advertising cookies, or third-party analytics. Browser storage is used for technical functions only:

  • When you post a comment, your browser stores a private code so you can delete your own comment from the same device.
  • The homepage slider remembers its position while your browser tab stays open.
  • A login session cookie is used only by site administrators in the admin panel, not by visitors.

Third parties and data transfers

To run the Site we rely on the following service providers, which may process data inside or outside Indonesia:

  • The hosting and server provider that runs the Site and its database.
  • The email service provider that forwards contact-form notifications to our team.
  • Google Fonts, which serves the Site’s typefaces, so your IP address may be received by Google.

We only share data to the extent needed for these services, or where required by law or by an order of a competent authority.

Retention and security

Contact messages are kept for no longer than 2 (two) years from receipt, to respond to and follow up on our correspondence with you, and are then deleted automatically. You can ask us to delete them sooner at any time. Comments are kept while the related article is published, or until you or a moderator delete them.

We apply reasonable technical and organisational measures to protect data, including encrypted connections (HTTPS), restricted, password-protected access to the admin panel, and submission rate limits to prevent abuse. No system is entirely free of risk. If a personal data protection failure occurs, we will handle it in accordance with applicable regulations.

Your rights

Under the Personal Data Protection Law, you have the right to:

  • Obtain information about how your personal data is processed and request a copy of it.
  • Correct data that is inaccurate or incomplete.
  • Request deletion of your data, or end its processing.
  • Withdraw consent you have given.
  • Object to the processing of your data.

To exercise these rights, email hello@surplusadvisory.id. We will verify your request and respond within the period required by law.

Changes and contact

We may update this policy from time to time. The latest version is always available on this page, with its update date shown at the top.

Questions about this policy can be sent to hello@surplusadvisory.id.