Privacy Policy
1. About this policy
This policy explains how kloterin.id ("we") collects, uses, stores, and protects personal data when you use the kloterin.id app. It is based on Indonesia's Personal Data Protection Law No. 27 of 2022 (UU PDP). Where an agency operates in another country, we also respect the data protection law that applies there, such as Malaysia's Personal Data Protection Act 2010 (PDPA), to the extent it applies to our role.
2. Our role and the agency's role
- Pilgrim data (identity, ID card, passport, contact details, documents, payments, signatures) is entered by the agency, by its agents, or by pilgrims themselves through the pilgrim portal or the public agency page. For this data the agency is the data controller and kloterin.id is the data processor, processing it only on the agency's instructions.
- User account data (name, email, and the activity of agency staff in the app) is managed by kloterin.id as data controller in order to run the service.
3. Data we process
- Account data: name, email address, and password. Passwords are stored with one-way encryption and we cannot see them.
- Agency data: agency name, company name, city, licence number, bank accounts, logo, contacts, packages, departures, registration forms, and terms & conditions.
- Pilgrim data entered by the agency or its agents: name, national ID number, place and date of birth, address, phone number, gender, marital status, passport details, other details required by the agency's form (for example occupation, education, blood type, height and weight, Hajj/Umrah history, and facial description for Hajj), document photos (ID card, passport, family card, photo, marriage certificate, vaccination certificate), payment records, and transfer receipts.
- Consent and signatures: the version of the agency's terms that was agreed, the date and time, how it was agreed (office, agent, or pilgrim portal), and the drawn signature image.
- Data sent by prospective pilgrims through the public agency page: name, WhatsApp number, city, number of people, the chosen departure, and notes. This is forwarded to the agency as a prospect.
- Subscription data: plan, amount, sender name, and transfer receipt, or the order and transaction reference from Midtrans or Stripe.
- Technical data: access times, device and browser type, and error logs, used to keep the service secure and improve it.
Reading ID card photos to fill in forms happens on your own device. The text on the card is not sent to a third-party service for reading.
4. Why we process data
- To run the app's features: pilgrim registration, seat tracking, payment records, documents, filled registration forms, consent records, agent commissions, the pilgrim and agent portals, the public agency page, brochures, and reports.
- To manage accounts, roles, and staff invitations.
- To process subscriptions and provide technical support.
- To keep the service secure, prevent misuse, and meet legal obligations.
We do not sell personal data, use it for advertising, or use pilgrim data for our own purposes.
5. Where data is stored
Data is stored with third-party cloud providers: Supabase (database, authentication, and file storage, in a Singapore data centre) and Vercel (serving the app pages). Data may therefore be processed outside Indonesia and outside your country. We choose providers whose security and data protection standards are equivalent to or higher than those required by UU PDP, in line with Article 56 of UU PDP.
6. How we protect data
- All connections to the app are encrypted (HTTPS/TLS).
- Each agency's data is separated at database level. One agency cannot open another agency's data.
- Menus and editing rights inside an agency follow the roles set by the agency owner. Agents only see their own pilgrims and commissions.
- The pilgrim portal only shows a pilgrim's own data through a personal link that expires after the trip and can be replaced by the agency at any time. It never shows national ID numbers or other pilgrims' data.
- The public agency page only shows packages the agency has published and seat counts. It never shows pilgrim data.
- Document photos and transfer receipts are kept in private storage and can only be opened through temporary links valid for about one hour.
- kloterin.id staff only access agency data for technical support requested by the agency, to verify subscription payments, or when required by law.
7. Who receives data
Data is shared only with the infrastructure providers above, as far as needed to run the service, or with authorities where required by law. If you pay for a Kloterin subscription through Midtrans, we send Midtrans the invoice number, plan, period, and amount. If you pay by card through Stripe, we send Stripe the order number, plan, period, amount, and your email for the receipt. Card and payment details you enter on the Midtrans or Stripe page are processed by them under their own policies; we never receive card numbers or payment credentials.
8. How long we keep data
Data is kept while the agency account is active. When an agency asks for its account to be deleted, agency and pilgrim data are deleted within 30 days of the request, unless the law requires us to keep it longer. The agency can export its data before deletion.
9. Your rights
- Pilgrims who want to see, correct, or delete their data can contact the agency they registered with, because the agency is the controller of that data. We will help the agency fulfil the request.
- Account users have the right to access, correct, and delete their personal data and to withdraw consent by contacting us. We respond within 3 x 24 hours.
10. Agency obligations
The agency must make sure it has a lawful basis, including the pilgrim's consent where required, before entering pilgrim data into kloterin.id. The agency should only enter data needed to organise Umrah and Hajj and must keep staff and agent accounts confidential.
11. Data breaches
If personal data protection fails, we will notify the affected agencies within 3 x 24 hours of becoming aware of it, including what data was affected, when and how it happened, and what we are doing about it, in line with Article 46 of UU PDP.
12. Storage on your device
The app stores your sign-in information, language, and display preferences in your browser so you stay signed in. The pilgrim portal stores the pilgrim's personal link on their phone. We do not use advertising cookies or third-party trackers.
13. Changes to this policy
If this policy changes, we will announce it in the app or by email before the change takes effect.
14. Contact
Questions, requests, or complaints about personal data can be sent to halo@kloterin.id.