Data Policy

REID Data Policy

PT Real Info Indonesia trading as REID
Registration No. 2111230048991
Version 2.2 | Effective 1 April 2025

1. Introduction

This Data Policy describes how PT Real Info Indonesia trading as REID ("REID") collects, manages, processes, and protects data in connection with its property market intelligence platform and services. It applies to all REID clients, platform users, data partners, and employees.

This policy should be read alongside REID's Terms of Service, Usage Policy, and Privacy and Cookie Policy, all available at www.realinfo.id. Capitalised terms used in this policy have the meanings given in those documents. Where this policy addresses personal data, it operates consistently with REID's Privacy and Cookie Policy and Indonesia's Personal Data Protection Law (UU PDP No. 27 of 2022).

2. Data We Hold

2.1 Property Market Data
REID's core dataset comprises property market intelligence for the Bali region, including:
• Short-term rental performance data including average daily rates (ADR), occupancy rates, and revenue metrics
• Leasehold and freehold transaction records and pricing data
• Neighbourhood and sub-region level market statistics
• Yield estimates and return analytics
• Emerging and key market trend data

This dataset currently contains over 100,000 records and is updated on a cadence determined by membership tier (see Section 4).

2.2 Personal Data
REID also processes personal data relating to platform users and clients. The collection and use of personal data is governed by REID's Privacy and Cookie Policy.

2.3 AI Query Data
REID retains AI query data submitted by REID Base, REID Pro, and REID Enterprise subscribers. Query data in identifiable form is retained for 24 months. After 24 months, query data is anonymised and aggregated, and retained indefinitely. Anonymised aggregate AI query data is used by REID as a market demand indicator to understand research patterns and improve REID's data products and AI capabilities. This use is disclosed in REID's Privacy and Cookie Policy and Terms of Service.

2.4 AI-Generated Outputs
REID's AI Features generate query responses, market analyses, and yield estimates using REID's proprietary dataset. AI-generated outputs are clearly identified as estimates and are subject to the limitations described in REID's Terms of Service. The ownership and permitted use of AI outputs is governed by Section 4.3 of the Terms of Service.

3. Data Sources
REID's property market dataset is compiled from multiple sources:
• Proprietary research and data collection conducted by REID's team
• Public records and government datasets
• Licensed third-party data providers under data supply agreements
• Platform user activity data in anonymised and aggregated form

REID does not guarantee the accuracy or completeness of data supplied by third parties and accepts no liability for errors in third-party source data. Where third-party data is used, REID applies validation processes to assess quality before publication.

Land price data is currently undergoing validation and is not yet published on the Platform. It will be disclosed as it is validated and released in stages.

4. Data Update Cadence

REID's dataset is updated on the following schedule by membership tier:
• REID Member: Aggregated market summaries updated quarterly
• REID Base: Dashboard data updated monthly
• REID Pro: Dashboard data updated monthly
• REID Enterprise: Live database access with monthly updates

REID endeavours to maintain data currency within these cadences but does not guarantee real-time accuracy. Market conditions can change rapidly and users should treat REID data as a research input rather than a definitive current market valuation.

5. Data Quality and Validation

5.1 Quality Standards
REID applies internal quality controls to its dataset including:
• Cross-referencing of data across multiple sources where available
• Statistical outlier detection to identify anomalous records
• Regular data audits to assess completeness and accuracy
• Validation of new data categories prior to Platform release

5.2 Limitations
Users should be aware of the following inherent limitations in REID's data:
• Data coverage varies by neighbourhood and market segment. Neighbourhood-level data takes priority where available; where it is not, proxy regional data may be used and will be disclosed as such.
• Yield calculations incorporate assumptions about operating costs. REID's standard market practice assumption is a 50% operating expense ratio unless actual cost data is provided. These are estimates, not audited financial figures.
• REID data does not constitute a formal property appraisal and does not include physical inspection of any property.
• Historical data may be revised retrospectively as REID's dataset is improved.

6. AI Data Processing

6.1 How AI Uses REID Data
REID's AI assistant accesses REID's proprietary dataset to respond to user queries. AI responses are generated based on available data at the time of query and are subject to the data limitations described in Section 5.2.

AI responses involving rate-based metric changes are expressed in percentage points, not percentages. Zero changes are expressed as flat. These conventions are applied consistently to ensure accuracy in AI-generated market commentary.

6.2 AI Output Integrity
REID's AI is configured to:
• Use only verified data from REID's proprietary dataset for calculations and market statistics
• Disclose when neighbourhood-level data is unavailable and proxy data is being used
• Avoid fabricating data or improvising figures not present in the dataset
• Clearly distinguish between market intelligence outputs and investment advice, which it does not provide

6.3 AI Output Ownership
The ownership and permitted use of AI-generated outputs is governed by Section 4.3 of REID's Terms of Service. In summary, outputs are licensed for use within the scope of each membership tier. Enterprise subscribers may negotiate broader commercial use rights under their Enterprise agreement.

6.4 AI Query Data Retention and Use
AI query data is handled in accordance with REID's Privacy and Cookie Policy. In summary:
• Identifiable query data is retained for 24 months
• After 24 months, data is anonymised and aggregated
• Anonymised aggregate data is retained indefinitely and used as a market demand indicator
• User query content is not shared with third-party AI providers for their own training purposes
• Individual query content is not used to retrain REID's AI models without explicit user consent

7. Data Access Controls

REID applies tiered access controls to its dataset:
• REID Members access aggregated, anonymised market summaries only
• REID Base subscribers access expanded market data through the Platform dashboard
• REID Pro subscribers access full neighbourhood-level data, AI features, and yield analytics
• REID Enterprise subscribers access REID's live database with custom reporting capabilities

Publicly and privately sourced data are separated within REID's systems. Access to personally identifiable data is restricted to authorised REID personnel on a need-to-know basis.

8. Data Minimisation

REID adheres to the principle of data minimisation. We collect and process only the data necessary for the delivery of REID Services. We review our data collection practices regularly to ensure continued compliance with this principle.

9. Data Protection

9.1 Security Measures
REID implements robust technical and organisational measures to protect data against unauthorised access, alteration, disclosure, or destruction. Measures include encryption, access control, secure data storage, and regular security assessments.

9.2 Data Protection Impact Assessments
REID conducts Data Protection Impact Assessments (DPIAs) for processing activities that present a risk to individual privacy rights. Privacy by Design and Privacy by Default principles are applied to all new data processing initiatives.

9.3 Sub-Processor Management
Where REID engages third-party sub-processors, including cloud providers, analytics platforms, and AI infrastructure providers, those processors are required to maintain data protection standards consistent with UU PDP and REID's internal policies, under binding contractual obligations. Where a new sub-processor is engaged or an existing one changed in a way that materially affects data processing, registered users will be notified with at least 14 days notice as described in the Privacy and Cookie Policy.

10. Data Subject Rights
Individuals whose personal data is held by REID have rights under UU PDP including the right to access, correct, delete, restrict, and port their data. REID will respond to all data rights requests within 14 business days of receipt. The exercise of these rights is described in full in REID's Privacy and Cookie Policy. To make a request, contact hello@realinfo.id.

Anonymised and aggregated data, including anonymised AI query data retained for market analytics, is not subject to individual deletion requests as it is no longer capable of identifying any person.

11. Intellectual Property in Data

REID's compiled dataset, methodologies, algorithms, and AI models are proprietary. All intellectual property rights in REID's data products are owned by or licensed to PT Real Info Indonesia. Users are licensed to access REID data within the scope of their membership tier only, and to use AI outputs as described in Section 4.3 of the Terms of Service.

Users may not extract, replicate, or redistribute REID data beyond their tier entitlement, or use REID data to create competing data products or train competing AI models without REID's prior written consent. These restrictions are enforced under REID's Terms of Service and Usage Policy.

12. Regulatory Compliance

REID's data practices are designed to comply with applicable Indonesian law, including:
• UU PDP No. 27 of 2022 (Personal Data Protection Law)
• UU ITE No. 11 of 2008 as amended (Electronic Information and Transactions Law)
• Applicable Bank Indonesia and OJK regulations where relevant to financial data

REID monitors regulatory developments and updates its data practices as required. Users operating under sector-specific regulatory frameworks are responsible for assessing whether REID data is suitable for their compliance purposes.

13. Changes to This Policy

This Data Policy may be updated periodically to reflect changes in REID's data practices, product features, or applicable law. Updates will be posted at www.realinfo.id/data-policy. Material changes will be communicated to registered users by email with at least 14 days notice before changes take effect.

14. Contact

For questions or concerns about REID's data practices, please contact:

Email: hello@realinfo.id
Entity: PT Real Info Indonesia trading as REID, Registration No. 2111230048991

REID Data Policy

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