Privacy Policy

This Privacy Policy applies to the website aeternadata.com, operated by PT Aeterna Data Intentio Logic, trading as Aeterna Data.

PT Aeterna Data Intentio Logic is the Data Controller for personal data collected through this website.

This Privacy Policy covers personal data collected through:

• This website (aeternadata.com) and any subdomains
• Contact and enquiry forms on this website
• Email correspondence with Aeterna Data

This policy does not cover personal data processed by Aeterna Data on behalf of its clients in the course of providing annotation services. That processing is governed by the Data Processing Agreement (DPA) executed between Aeterna Data and each client.

We collect only the personal data you actively provide to us. We do not collect data silently or without your knowledge.

Contact and enquiry forms:

• Full name
• Business email address
• Company name
• Country
• Project description or message content

Automatically collected data:

• IP address (for security and abuse prevention)
• Browser type and version
• Pages visited and time spent (via analytics, if enabled)
• Referring URL

We do not collect or process any special categories of personal data (sensitive data) through this website.

We process your personal data under the following legal bases as defined by GDPR Article 6:

• Legitimate interests (Article 6(1)(f)): To respond to business enquiries and evaluate potential commercial engagements.
• Contractual necessity (Article 6(1)(b)): Where processing is necessary to take steps prior to entering into a contract with you.
• Consent (Article 6(1)(a)): Where you have explicitly consented, such as by submitting a contact form with a consent checkbox. You may withdraw consent at any time by contacting us.
• Legal obligation (Article 6(1)(c)): Where processing is required to comply with applicable law.

We use personal data collected through this website for the following purposes:

• To respond to your enquiry or project brief
• To send a scoping proposal or Statement of Work
• To schedule discovery calls or consultations
• To comply with our legal obligations
• To improve this website and our services

We do not use your data for unsolicited marketing. We do not sell, rent, or trade your personal data to any third party.

We do not sell or share your personal data with third parties for their own marketing purposes.

We may share your data with:

• Service providers: Third-party tools used to operate this website (e.g. hosting, email delivery, analytics). These providers act as Data Processors under binding agreements and may not use your data for their own purposes.
• Legal authorities: Where required by applicable law, court order, or regulatory requirement.
• Professional advisers: Legal counsel or auditors, under strict confidentiality obligations.

Where any third-party processor is located outside the EU/EEA, appropriate transfer safeguards (including EU Standard Contractual Clauses) are in place.

PT Aeterna Data Intentio Logic is established in Indonesia, outside the EU/EEA. Where personal data is transferred from the EU/EEA to Indonesia, such transfers are governed by EU Standard Contractual Clauses (SCCs) — Module 1 (Controller-to-Controller) as adopted by Commission Implementing Decision (EU) 2021/914.

By submitting an enquiry through this website, you acknowledge that your personal data may be transferred to and processed in Indonesia under the safeguards described above.

A copy of the applicable SCCs is available upon request at: [email protected]

This website may use cookies and similar tracking technologies. A cookie is a small text file placed on your device to help the website function and to collect usage data.

Types of cookies we may use:

• Strictly necessary cookies: Required for the website to function. Cannot be disabled.
• Analytics cookies: Used to understand how visitors interact with the website. Only placed with your consent.
• Preference cookies: Used to remember your settings and preferences.

You can manage or disable cookies through your browser settings at any time. Disabling strictly necessary cookies may affect website functionality.

For full details, see our Cookie Policy.

We retain personal data only for as long as necessary for the purpose for which it was collected:

• Enquiry and contact data: Retained for up to 24 months from last contact, unless a commercial engagement follows — in which case retention is governed by the applicable contract.
• Website analytics data: Retained for up to 12 months.
• Legal and compliance records: Retained for the period required by applicable law (typically 5–7 years).

After the applicable retention period, personal data is securely deleted or anonymised.

If you are located in the EU/EEA, you have the following rights regarding your personal data:

• Right of access: Request a copy of the personal data we hold about you.
• Right to rectification: Request correction of inaccurate or incomplete data.
• Right to erasure: Request deletion of your personal data where there is no legitimate reason to continue processing it.
• Right to restriction: Request that we restrict processing of your data in certain circumstances.
• Right to data portability: Receive your data in a structured, machine-readable format.
• Right to object: Object to processing based on legitimate interests.
• Right to withdraw consent: Where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at: [email protected]

We will respond within 30 days. We may need to verify your identity before processing your request.

If you believe your personal data has been processed unlawfully, you have the right to lodge a complaint with the relevant supervisory authority in your EU/EEA member state.

You may lodge a complaint with the data protection supervisory authority in the EU/EEA member state where you reside, work, or where the alleged infringement took place. A list of EU/EEA supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.

These measures include:

• Encrypted data transmission (TLS/HTTPS)
• Access controls limiting who can access personal data
• Regular review of security practices
• Contractual security obligations on all data processors

No method of transmission over the internet is 100% secure. While we take reasonable precautions, we cannot guarantee absolute security.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. The updated policy will be posted on this page with a revised 'Last updated' date.

We encourage you to review this policy periodically. For material changes, we will make reasonable efforts to notify affected individuals.