Privacy Policy

1. Data controller

DOMA is a brand operated by PT MIRONOV DREAMS PROJECT, a company registered in Kabupaten Gianyar, Republic of Indonesia, NPWP 406566547907000 (“DOMA”, “we”, “us” or the “Company”).

Company registration number: AHU-0027378.AH.01.11.TAHUN 2025. Ministry of Law approval: AHU-0008343.AH.01.02.TAHUN 2025, dated 10 February 2025.

PT MIRONOV DREAMS PROJECT determines the purposes and means of processing described in this Policy.

2. Scope

This Policy applies to data received through domabali.com, website forms and quizzes, Facebook and Instagram lead forms, WhatsApp, Telegram, email, consultations, property viewings and subsequent communications.

3. Data we collect

Information you provide

• name and surname;
• phone number, email address and messenger username;
• country of residence and preferred language;
• projects of interest, budget, investment goals, purchase timeline and questionnaire answers;
• the content of correspondence, enquiries and contractual communications.

Information collected automatically

• IP address, browser and device type, operating system;
• pages viewed and date and time of access;
• referring address, UTM tags and advertising campaign;
• cookie identifiers, including _fbp and _fbc, if you accept advertising cookies;
• events relating to your interaction with the website and DOMA advertising.

4. Purposes and legal bases

We use personal data to:

• respond to enquiries, recommend a property and prepare an offer;
• arrange a consultation, presentation, viewing or negotiation;
• take steps at your request before entering into a contract and perform a contract;
• send DOMA offers and updates where consent has been given;
• measure advertising performance and improve the website and service;
• maintain security and prevent spam and fraud;
• comply with law and establish, exercise or defend legal claims.

The legal basis may be your consent, steps requested before a contract, performance of a contract, compliance with a legal obligation, or DOMA’s legitimate interests where they are not overridden by your rights.

We may use data for advertising attribution and campaign optimisation, but we do not make solely automated decisions that produce legal or similarly significant effects for you.

5. Who receives data

Access is limited to staff and contractors who need the information to handle your enquiry. Service providers may include:

• Meta Platforms — Facebook, Instagram, Meta Pixel and Conversions API;
• Cloudflare — hosting, website protection and lead transmission;
• Notion — enquiry and customer relationship records;
• WhatsApp and Telegram — communications;
• analytics, hosting and technical-support providers;
• lawyers, notaries, advisers, transaction partners and public authorities where necessary or required by law.

DOMA does not sell personal data. Providers may use data only to deliver the relevant service or under another lawful basis stated in their own terms.

6. International transfers

Some providers may process data outside Indonesia. For international transfers we use the mechanisms available under Indonesia’s Law No. 27 of 2022 on Personal Data Protection (UU PDP): assessing the destination’s level of protection, applying contractual or other appropriate safeguards, or obtaining consent where required.

7. How long we keep data

• prospective-client enquiries and correspondence — up to 24 months after the last meaningful interaction;
• marketing contacts — until consent is withdrawn, and no longer than 24 months without interaction;
• technical logs and advertising identifiers — up to 12 months;
• contractual, accounting and legal records — for the period required by applicable law or reasonably needed to protect legal claims.

After the applicable period, data is deleted or anonymised unless continued retention is required by law.

8. Cookies and advertising technologies

The website uses technologies necessary for its operation. With your consent, we also use analytics and advertising cookies, including Meta Pixel, to measure visits, enquiries and advertising performance.

Rejecting optional cookies does not restrict access to the website or its forms. You can change your choice below or delete cookies in your browser settings.

9. Your rights

Where provided by law, you may request information about processing, access and a copy, correction, withdrawal of consent, cessation, restriction or deletion, object to marketing, request portability, challenge an automated decision, and seek compensation.

We may verify your identity to protect your information. Withdrawal does not affect processing already lawfully completed. Requests are handled within the time limits required by applicable law.

10. Security and incidents

We use reasonable organisational and technical safeguards, including access restrictions, secure transmission, supplier controls and backups. No storage method can guarantee absolute security. If a personal-data breach occurs, we will provide any notices required by law within the applicable time limits.

11. Children

DOMA’s investment offers are intended for adults. We do not knowingly collect lead-form data from anyone under 18 or target minors with lead-generation advertising.

12. Changes and contact

We may update this Policy when our website, providers or legal obligations change. The latest revision date will always appear at the top of this page.