Privacy Policy

1. Who we are

Trawaya is a real-estate brokerage and development service based in Gili Trawangan, West Nusa Tenggara, Indonesia. For any privacy matter, you can reach us at hello@trawaya.com.

2. Information we collect

Information you give us directly. When you submit our contact form or email us, we collect the details you choose to share: your name, email address, phone number, investment budget and interests, and the content of your message.

Information collected automatically. When you browse the Site, we and our service providers automatically receive technical data such as your IP address, approximate location (city/country level), device and browser type, language, pages viewed, time spent, referring website, and interactions with page elements (for example clicks, scrolling and use of our yield calculator). This is collected through cookies and similar technologies described in section 5.

We do not intentionally collect sensitive categories of data (such as health, religion or biometric data), and we ask you not to submit them through our forms.

3. How we use your information

To respond to your enquiries, send you the project information you request, and arrange calls or meetings.

To operate, secure and improve the Site — including understanding which content is useful, fixing problems and preventing abuse or spam.

To measure the performance of our content and, in the future, of our marketing campaigns.

To comply with legal obligations and to establish, exercise or defend legal claims.

We do not sell your personal data.

4. Legal bases for processing (GDPR)

Where the GDPR applies, we rely on: (a) your consent — for example when you submit the contact form or accept non-essential cookies; (b) our legitimate interests — operating and improving the Site, securing it, and marketing our services in a proportionate way; (c) performance of a contract or steps prior to a contract — when we prepare an investment or service agreement with you; and (d) legal obligation — where the law requires us to keep or disclose information.

You may withdraw consent at any time; this does not affect processing carried out before the withdrawal.

5. Cookies and analytics

We use cookies and similar technologies (such as scripts and pixels) to make the Site work and to understand how it is used.

Google Analytics 4 (GA4). We use GA4 to measure visits and interactions. GA4 sets cookies and collects usage data (including truncated/approximate location and device information). We have configured event data retention to 14 months. You can learn how Google uses data from partner sites at policies.google.com/technologies/partner-sites and opt out of Google Analytics with the browser add-on at tools.google.com/dlpage/gaoptout.

Google Tag Manager (GTM). We use GTM to manage the measurement scripts on the Site. GTM itself does not persistently collect personal data; it loads the tools described in this policy.

Server-side measurement. When you submit the contact form, we may also record a conversion event on our own server (via the GA4 Measurement Protocol) so that we can count enquiries accurately.

You can control or delete cookies in your browser settings at any time; the Site remains usable without non-essential cookies.

6. Advertising and remarketing

We may run advertising campaigns with third-party platforms such as Google Ads, and social platforms, and may enable their measurement or remarketing features on the Site.

Where such features are active, third-party vendors, including Google, use cookies to serve ads based on your prior visits to this Site. Google's use of advertising cookies enables it and its partners to serve ads to you based on your visits to this Site and/or other sites on the Internet.

You may opt out of personalised advertising by Google at adssettings.google.com, and of personalised advertising by many other vendors at aboutads.info/choices or youronlinechoices.eu.

Where required by law (for example for visitors from the European Economic Area or the United Kingdom), we will ask for your consent before activating advertising cookies.

7. Who we share data with

Service providers who process data on our behalf and under our instructions: Google (analytics, tag management and, in future, advertising), Vercel (website hosting and delivery), and Cloudflare (domain, DNS and network security). Each provider only receives what it needs to perform its service.

Professional advisers and authorities, where necessary to comply with law, enforce our terms, or protect rights, safety and property.

We do not share your data with third parties for their own independent marketing.

8. International data transfers

Our service providers may process data in countries other than your own, including the United States, the European Union, Singapore and Indonesia. Where data is transferred out of a jurisdiction that restricts such transfers, we rely on appropriate safeguards such as the providers' standard contractual clauses and equivalent mechanisms.

9. How long we keep data

Enquiry data: for as long as needed to handle your enquiry and any resulting relationship, after which it is deleted or anonymised.

Analytics event data: 14 months (our configured GA4 retention), after which it is deleted by Google.

We may keep specific records longer where the law requires it or where they are needed for legal claims.

10. Your rights

Depending on your location, you may have the right to: access the personal data we hold about you; receive a copy in a portable format; correct inaccurate data; delete data; restrict or object to processing (including direct marketing); and withdraw consent.

To exercise any right, email hello@trawaya.com. We will respond within the time required by applicable law. If you are in the EEA or UK, you also have the right to lodge a complaint with your local data protection authority; in Indonesia, with the competent authority under UU PDP.

11. Children

The Site is aimed at adult investors and is not directed at anyone under 18. We do not knowingly collect data from children; if you believe a child has provided us data, contact us and we will delete it.

12. Security

We protect data with measures including HTTPS encryption across the Site, strict security headers, DNSSEC-protected DNS, access controls on our accounts and infrastructure, and spam protection on our forms. No method of transmission or storage is 100% secure, but we work to protect your data in line with industry practice.

13. Third-party links

The Site may link to external websites and services we do not control. Their privacy practices are governed by their own policies, which we encourage you to read.

14. Changes to this policy

We may update this policy as our services or the law evolve. The date at the top shows the latest revision; material changes will be highlighted on the Site. Continued use of the Site after changes take effect means the updated policy applies.

15. Contact

Trawaya — Gili Trawangan, West Nusa Tenggara, Indonesia. Email: hello@trawaya.com. We answer privacy requests as a priority.