Last updated: 2026
This Privacy Policy explains how Sumbavillainvestment (an independent Sumba, Indonesia guide and concierge website), operated by Bali Premium Trip and published by Juara Holding Group (“we”, “us”, or “our”), collects, uses, discloses, and protects your personal data when you visit or use our website and related services.
We are committed to respecting your privacy and complying with applicable data protection laws, including Indonesia’s Personal Data Protection Law (Undang-Undang Pelindungan Data Pribadi, “UU PDP” No. 27/2022) and, where it applies, the General Data Protection Regulation (“GDPR”) for visitors from the European Union and the United Kingdom.
Who We Are and Contact Details
Sumbavillainvestment is an informational and concierge service website dedicated to Sumba, Indonesia. The website is operated by Bali Premium Trip and published by Juara Holding Group.
If you have any questions or requests regarding this Privacy Policy or our handling of your personal data, you can contact us at:
Email: sales@balipremiumtrip.com
Personal Data We Collect
Information You Provide Directly
We may collect the following personal data when you contact us or use forms on our website:
- Contact form details: Name, email address, phone number (if provided), and any other information you choose to include in your message or inquiry.
- Concierge or booking inquiries: Travel plans, preferred dates, group size, accommodation interests, and other details related to your request.
- Communication records: Copies of emails, messages, and related correspondence between you and us.
Information Collected Automatically
When you visit our website, certain technical information is collected automatically:
- Server logs: IP address, browser type and version, device type, operating system, referring URLs, pages visited, date and time of access, and error logs.
- Analytics data: Cookies and similar technologies may collect information about how you use our website, such as pages viewed, time spent on pages, clicks, and geographic region (approximate, based on IP address).
This information is generally collected in aggregate form and does not directly identify you, but may be considered personal data when linked with other information.
Information from Third-Party Communication Tools
- Email: If you email us, we will process your email address, message content, and any attachments.
- WhatsApp or similar apps: If we communicate via WhatsApp or other messaging platforms, we may process your phone number, profile name, and message content.
How We Use Your Personal Data
We use your personal data for the following purposes:
- Providing services and responding to inquiries: To answer your questions, provide local guidance and concierge support, prepare proposals, and follow up on your requests.
- Website operation and improvement: To operate, maintain, and improve the performance and content of our website and services.
- Analytics and statistics: To understand how visitors use our website, measure traffic and usage trends, and improve user experience.
- Security and fraud prevention: To protect our website, systems, and users from misuse, unauthorized access, and other unlawful activity.
- Legal compliance: To comply with legal and regulatory obligations and respond to lawful requests from authorities.
Where required by law, we will obtain your consent for certain types of processing, such as the use of non-essential cookies or sending marketing communications. You can withdraw your consent at any time by contacting us or adjusting your cookie settings (where available).
Legal Bases for Processing (GDPR)
For visitors from the EU/UK, we rely on the following legal grounds under the GDPR:
- Performance of a contract or steps prior to entering a contract: When we process data to respond to your inquiries or provide requested services.
- Legitimate interests: To operate and improve our website, maintain security, and perform basic analytics, provided that these interests are not overridden by your rights and interests.
- Consent: For certain types of analytics cookies or communications where consent is required.
- Legal obligation: When processing is necessary to comply with applicable laws.
Cookies and Analytics
Our website uses cookies and similar technologies to collect and store certain information when you visit.
What Are Cookies?
Cookies are small text files placed on your device by websites you visit. They are used to make websites work, improve functionality, and provide information to site owners.
Types of Cookies We Use
- Strictly necessary cookies: Required for basic site operation (e.g., security, load balancing). You cannot opt out of these cookies using standard cookie settings.
- Analytics/performance cookies: Used to understand how visitors use our site, which pages are most visited, and how users move around the site. This helps us improve our content and layout.
Where required by law, we will ask for your consent before placing analytics cookies on your device. You can usually control and delete cookies through your browser settings. Disabling cookies may affect some features of the website.
Third Parties and Data Sharing
We may share your personal data with the following categories of third parties, only to the extent necessary for the purposes described in this Policy:
- Web hosting and infrastructure providers: Companies that host our website, provide technical support, and store data on our behalf.
- Analytics providers: Services that help us analyze website traffic and usage trends.
- Communication providers: Email service providers and messaging platforms (including WhatsApp) used to send and receive communications.
- Professional advisers: Legal, accounting, or consulting professionals where necessary to protect our rights or comply with legal obligations.
- Authorities and law enforcement: Where we are legally required to share information, or where disclosure is necessary to protect our rights, users, or the public.
We do not sell your personal data. Third parties that process data on our behalf act as data processors and are bound by contractual obligations to protect your data and use it only for the specified purposes.
International Transfers of Personal Data
Our website and services may be operated from, or supported by providers located in, countries outside your own, including countries outside Indonesia and the EU/UK. This means your personal data may be transferred to and processed in other jurisdictions that may have different data protection laws.
For EU/UK visitors, where we transfer personal data to countries not recognized as providing an adequate level of data protection, we implement appropriate safeguards (such as standard contractual clauses or equivalent safeguards) where required by applicable law.
Data Retention
We keep your personal data only for as long as needed for the purposes described in this Policy, or as required by law. In general:
- Contact and inquiry data: Retained for the duration of our communication and for a reasonable period afterward to manage follow-ups, disputes, or legal claims.
- Analytics data: Stored for the periods necessary to analyze usage trends and maintain website performance, typically in aggregated or anonymized form where possible.
- Server logs: Retained for a limited period for security, troubleshooting, and auditing purposes.
When personal data is no longer needed, we will delete it or anonymize it in a way that it can no longer be linked to you.
Data Security
We take appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures may include access controls, encryption in transit where applicable, secure server configurations, and internal policies on data handling.
No method of transmission over the internet or method of electronic storage is completely secure. While we aim to protect your personal data, we cannot guarantee absolute security.
Your Rights Under Indonesian Law (UU PDP)
Under UU PDP No. 27/2022, you have certain rights regarding your personal data, including (subject to conditions in the law):
- The right to obtain information about the clarity of identity, legal basis, and purpose of processing.
- The right to access and obtain a copy of your personal data we hold.
- The right to correct or update inaccurate or incomplete personal data.
- The right to end processing, delete, or anonymize your personal data in certain circumstances.
- The right to withdraw consent where processing is based on your consent.
- The right to object to certain types of processing.
- The right to complain to the relevant authorities if you believe your data protection rights have been violated.
To exercise these rights, please contact us using the email address provided in this Policy. We may ask you to verify your identity before responding to your request.
Your Rights Under the GDPR (EU/UK Visitors)
If you are located in the EU or UK, you may have the following rights under the GDPR, subject to certain limitations:
- Right of access: To obtain confirmation of whether we process your personal data and to receive a copy.
- Right to rectification: To have inaccurate or incomplete personal data corrected.
- Right to erasure: To request deletion of your personal data in certain circumstances (“right to be forgotten”).
- Right to restriction: To request that we limit processing of your personal data in certain cases.
- Right to data portability: To receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller where technically feasible.
- Right to object: To object to processing based on legitimate interests, and to object at any time to processing for direct marketing.
- Right to withdraw consent: Where processing is based on consent, to withdraw your consent at any time.
- Right to complain: To lodge a complaint with a supervisory authority in your country of residence or where you believe an infringement has occurred.
To exercise any of these rights, please contact us at sales@balipremiumtrip.com. We will respond in line with applicable legal requirements.
Children’s Data
Our website and services are not directed to children under 18 years of age, and we do not knowingly collect personal data from children under 18. If you believe that a child has provided us with personal data without appropriate consent, please contact us. We will take steps to delete such information where required by law.
Links to Other Websites
Our website may contain links to third-party websites or services. These websites have their own privacy policies, and we are not responsible for their content, practices, or policies. We encourage you to review the privacy policies of any third-party sites you visit.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will revise the “Last updated” date at the top of this page.
Your continued use of our website after any changes to this Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how we handle your personal data.
How to Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:
Email: sales@balipremiumtrip.com