Privacy Notice

This Privacy Notice (the "Notice") applies to every person whose Personal Data we process through the Nadi Pasien application, the Nadi Mitra application, the Nadi website, and Operators, including Users, persons who use SOS without an Account, persons for whom Services are ordered, Volunteer Crew Members, Managers, Owners, Partner Organisations, and persons who fill in forms on the website.

Nadi, domiciled at Jl. Pucung No. 97 RT 04 RW 02, Balekambang, Jakarta Timur 13530 ("we", "us" or "our"), is the Personal Data Controller for the Processing described in this Notice.

This Notice is a notice about the Processing of Personal Data, not a request for consent. When registering an Account, you agree to the Terms and declare that you have read this Notice by continuing on the registration screen, and that declaration is recorded together with its version and time. Volunteer Crew Members, Managers, and Owners personally agree to the Partner Terms and declare that they have read this Notice by pressing "Saya setuju" ("I agree") the first time they sign in to the Nadi Mitra application.

The declaration of having read this Notice referred to in Article 1.3 is not a basis for Processing; the bases for Processing are described in Article 6. Processing of health data and sending of promotional material are carried out only with your consent, given separately and explicitly. SOS does not require consent because it is processed to protect vital interests.

This Notice is read together with the General Terms of Use and the Partner Terms, but is not part of the agreement to those Terms.

From Users with an Account:

From SOS Users without an Account: telephone number, name if given, location, the information you write, and the Order. The Order is identified through the telephone number and a code stored on your device. While an SOS Order is waiting for the Crew to arrive, we also record the last time the Application was opened and whether the Application is running in the background, so that the Operator can contact you if the Application stops responding.

About persons for whom Services are ordered: data provided by the person placing the Order, including the Patient's name, condition, and information. In a mass-casualty incident, the Operator may record visible information about casualties, such as estimated age group, sex, and characteristics, to arrange pickup.

From Users who order through an Operator: name, telephone number, location, and Order details recorded by the Operator, the agreement to the Terms and the consent to the Processing of health information recorded by the Operator, as well as records of the Operator's telephone calls relating to the Order.

From Partners:

From Partner Organisations: organisation name, garage address, Units and their documents including proof of insurance, organisation bank account, Ledger, Bids, the PKS (Cooperation Agreement) and its annexes, and submissions of new Units or Volunteer Crew Members, including the name, WhatsApp number, and photo of the SIM of the proposed Volunteer Crew Member.

From website visitors: entries in the partner registration form (organisation name, name of the person in charge, WhatsApp number, city, number of ambulances, and notes), entries in the Account deletion form (WhatsApp number, account type, name, and reason), as well as the IP address and access time recorded by our website service provider for security.

Technical connection data: while the Application is in use, we record the number and type of requests that fail or time out, the time of the last successful connection, the duration of disruptions, the network type and whether that network is connected to the internet, the real-time connection status, the Application status (open or running in the background), the operating system and its version, the Application version, whether an Order is in progress, and a random code generated by the Application on your device. This data is not linked to the Account, name, telephone number, location, or Order content, and is used only to detect and fix connection disruptions.

Directly from you, when you register, order, fill in your profile, or send ratings, reports, messages, or forms.

From your device, in accordance with the permissions you give the Application: location, the device code for delivering notifications, permission status, error reports, and technical connection data.

From persons who order Services for you, and from Operators who record Orders by telephone, by WhatsApp, or at the scene.

From the Crew, Operators, and Partner Organisations carrying out Orders: trip stages, pickup notes, schedules, and Crew Pay.

From our payment service provider: payment status, the linking code of the payment account you link, and the result of verifying the name of the withdrawal account holder.

From our admins: the results of verifying Partners' documents and profile photos, and the Eligibility of Partner Organisations.

From our own systems, which generate data such as unusual-pattern flags and fake-location detection, as described in Article 7.3.

We process Personal Data on the bases for Processing referred to in Article 20 of the UU PDP, namely:

You give consent to health data separately when filling in the medical profile or the information on the Patient's condition, through a statement displayed next to the save button, which explains that the data is used only to prepare the Crew carrying out the Order. For Orders placed through an Operator, your consent to the health information you give is recorded by the Operator. That consent is recorded together with its time.

Providing health data is not mandatory, and Orders can still be placed without it. You may withdraw consent by clearing the medical profile through the Account. Withdrawal of consent does not affect the lawfulness of Processing carried out before it.

SOS is processed to protect the vital interests of the person who needs help. Therefore, SOS does not require an Account, consent, or a declaration of age, and your number and location are forwarded directly to the Operator.

Account holders are at least 18 (eighteen) years of age. A child's Personal Data is provided by a parent or guardian, who gives consent on the child's behalf. If you provide another person's data, including their health data, you declare that you are authorised to provide it or that you are providing it to protect that person's vital interests.

An Account known to be owned or used by a child under 18 (eighteen) years of age may be reported through the Bantuan (Help) menu or to the Data Protection Officer at halo@nadisehat.id. We examine every report and, if the report is substantiated, suspend that Account and delete the child's Personal Data as set out in Article 15.

We use Personal Data to:

Personal Data is not sold, not exchanged, and not used for third-party advertising.

Decisions made automatically. Our systems take the following actions without human intervention:

Users. Location is read when you set the pickup point and while an Order is in progress with the Application open. Beyond that, the Application does not track you, and the Nadi Pasien application does not request background location permission.

Volunteer Crew Members. While on Standby or while an Order is in progress, the device's position is sent continuously, including when the Nadi Mitra application is closed or not in use, through the "sepanjang waktu" ("all the time") location permission. This tracking is based on the performance of the Partner Terms and the legitimate interest in the safety of Users and Crew, and notice of it is given on the consent screen of the Nadi Mitra application before the Volunteer Crew Member first goes on Standby. The position is used to offer Orders to the nearest Unit, display the ambulance's position to the User and holders of the trip-sharing link, replay the route in the event of a complaint, incident, or dispute, and detect fake locations.

Sending of the position stops when the Volunteer Crew Member is no longer on Standby and has no Order in progress. The last position is overwritten each time a new position is received. Trip tracks are kept for 90 days and then deleted automatically, except the tracks of Orders that are the subject of a safety incident, complaint, or dispute under examination, which are held until that examination is complete. The position at each change of Standby status is kept for 90 (ninety) days.

Volunteer Crew Members may stop tracking by ending Standby after the Order in progress is completed, or by revoking location permission. Without location permission, a Volunteer Crew Member cannot go on Standby and does not receive Orders.

Managers and Owners. The location of Managers and Owners is not tracked, except when the person concerned is on Standby as a Volunteer Crew Member.

Our map provider (Mapbox) receives the technical data needed to display maps, namely the IP address and device and Application information, when a map is displayed in the Application and on the trip tracking page. The sending of optional telemetry data to the map provider is disabled in the Application.

Personal Data is disclosed only to the parties, and only to the extent, described below:

Access to Personal Data is limited according to the responsibilities of each party.

The following Processors process Personal Data on our behalf, are bound by data protection agreements, and receive only the part of the data needed for their role:

The current list of Processors and their processing locations may be requested from the Data Protection Officer. The addition of Processors is notified as set out in Article 20.

Personal Data may be stored and processed inside Indonesia or outside Indonesia, including by the Processors in Article 10 in the countries where each of them processes data.

In accordance with Article 56 of the UU PDP, we transfer Personal Data outside Indonesia only on one of the following bases:

For the Processors in Article 10 that process Personal Data outside Indonesia, we use the basis referred to in Article 11.2 point (b), unless the destination country meets point (a). The transfer basis for each Processor may be requested from the Data Protection Officer.

Every data transmission is encrypted.

If the Applicable Laws and Regulations require a type of data, including health data or financial records, to be stored or processed within Indonesia, we will store or process that data within Indonesia.

Personal Data is kept for the following periods, and then deleted or anonymised automatically:

Data held as evidence for an incident, complaint, or dispute under examination is kept until the examination is complete, and then follows the periods above.

Access to Personal Data is restricted by role, so that each party can open only the data needed for its responsibilities.

Passwords are protected so that they are not stored as readable text. Verification codes are sent via WhatsApp. Repeated failed sign-in attempts may lock the account temporarily.

A Partner account can be signed in on only one device at a time if that setting is applied. Our personnel's access to internal consoles is protected by additional verification, recorded in the activity log, and reviewed periodically.

Partner documents are kept in private file storage. Partner profile photos can be opened through their link because they are displayed to Users.

All data transmissions are encrypted. We never ask for your PIN, OTP code, or banking password.

In accordance with the UU PDP, you have the right to:

How to exercise those rights:

Every request is answered no later than 3 × 24 (three times twenty-four) hours after we confirm that the requester is the owner of the data, through the signed-in Account session or through verification to the WhatsApp number concerned.

We may refuse or postpone acting on a request to the extent permitted by the UU PDP, for example because the data must be kept to fulfil a legal obligation, notifying you of the reason.

If your objection is not resolved, you may complain to the Personal Data protection authority referred to in the UU PDP or, before that authority is established, to the ministry responsible for government affairs in the field of communications and digital affairs.

You may request deletion of your Account through the Application, at Akun → Privasi & data → Minta penghapusan akun (Account → Privacy & data → Request account deletion) in Nadi Pasien or at Profil → Hapus akun (Profile → Delete account) in Nadi Mitra, or, without the Application, through the Account Deletion page.

Our personnel review the request and confirm ownership of the Account before deleting it. We respond no later than 3 × 24 (three times twenty-four) hours and complete the deletion no later than 30 (thirty) days after identity is confirmed. Confirmation is sent via WhatsApp after deletion is complete.

Order and payment records are kept in anonymised form for the periods in Article 12, namely 10 (ten) years for paid Orders and 5 (five) years for SOS and Social Service Orders, containing only the area (kecamatan or sub-district, and city) and coordinates rounded to approximately 1 km, and without name, telephone number, or health data. Details of the data that is deleted and the data that is retained are described on the Account Deletion page.

If a Personal Data Protection Failure occurs, we give written notice no later than 3 × 24 (three times twenty-four) hours to you, through the Application, WhatsApp, or email, and to the authority referred to in Article 14.5.

That notice states the Personal Data exposed, when and how the Personal Data was exposed, the handling and recovery efforts we have made, and the steps you need to take.

We record every Personal Data Protection Failure together with its handling.

The Application stores the sign-in session, the number you asked to be remembered, Standby status (Nadi Mitra application), permission settings, and the code of an SOS Order without an Account in the Application's storage on your device.

The website uses only the browser storage needed for pages to function, and does not use advertising cookies or third-party trackers.

That data is removed when you sign out of the Account or delete the Application or browser data.

The Application may open third-party applications or sites, for example navigation applications, the GoPay application, the Midtrans payment page, or WhatsApp. The Processing of Personal Data by those third parties is subject to their respective privacy policies.

We send promotional material about Nadi's Services only if you turn on the promotional setting in the Account. That setting is off by default, and your consent is recorded together with its time.

That consent applies to both mobile notifications and WhatsApp, and you may withdraw it at any time by turning off the promotional setting.

Promotional material is not inserted into notices about Orders. Notices about Orders are still sent because they are needed to carry out Orders.

We do not share your Personal Data with third parties for their marketing purposes.

We may update this Notice. Each version is given a version number and an effective date, and is recorded in the Revision History.

Changes that add types of Personal Data, purposes of Processing, Processors, or transfer destination countries are notified through the Application before they take effect. If such a change concerns Processing based on consent, we ask for your consent again before processing.

We appoint a Data Protection Officer as referred to in Article 53 of the UU PDP:

The Data Protection Officer receives and handles requests from Personal Data subjects, monitors our compliance with the UU PDP, and serves as the contact person for the competent authority.