Pilot version — draft, pending legal review.
Dukuku by Rasio Labs, Pilot Privacy Policy
Effective: [TANGGAL BERLAKU]. Last updated: . Operator: Rasio Labs, Seturan, Sleman, Yogyakarta. Data protection contact: dev@rasio.ai.
Summary
- We are the Controller for Merchant accounts; for customer data, the Merchant is the Controller and We are the Processor.
- We never sell data, never use it for advertising, and use no analytics/advertising/third-party tracking cookies.
- Data is stored on Contabo servers (Singapore); 14-day backups; deleted within 30 days after you leave.
- You can access, correct, delete, and get a copy of your data; we respond within 3×24 hours.
- Data protection failures are reported to the Merchant within 24 hours.
1. Our role
For Merchant accounts and their staff in the dashboard, We are the Controller. For customer and staff data that the Merchant manages in the POS/rental/web order/booking apps, the Merchant is the Controller and We are the Processor, acting on the Merchant’s instructions.
2. Data we process
- (a) account: name, email, password (stored hashed), sign-in log (IP address, device), 2FA;
- (b) business: name, address, logo, QRIS data, menu/fleet, transactions, reports;
- (c) staff: name, PIN (hashed), optional phone/email;
- (d) POS customers: name, phone, email, address, points, balance, notes;
- (e) web order customers: name, phone, order contents;
- (f) rental customers: name, phone, national ID/driving licence number, email, address, ID card photo (optional, private), vehicle hand-over photos, consent to be contacted via WhatsApp;
- (g) automatic technical data: IP address and user agent (browser/device type) at sign-in and during a session; audit log of security and admin actions (time, action, IP, user agent); name of each POS device paired to a store, with its pairing and last-sync time.
3. How we collect data
- From the Merchant and staff: when signing up, filling in the business profile and menu/fleet, and using the POS.
- From the Merchant’s customers: through web order and booking forms they fill in themselves, or as recorded by the Merchant’s staff.
- Automatically: browser cookies and local storage, sign-in logs, and server audit logs.
4. Cookies and local storage
| Name | Purpose | Duration | Type |
|---|---|---|---|
*.session_token | Keeps you signed in | 30 days since last activity | Essential cookie |
*.session_data | Signed session cache (fewer database reads) | 5 minutes | Essential cookie |
dukuku-locale | Remembers your language | 1 year | Functional cookie (+ local storage copy) |
theme | Remembers light/dark theme | Until cleared | Local storage, functional |
dukuku.activeOrgId | Remembers the active business | Until cleared | Local storage, essential |
Signing in may set other short-lived temporary cookies (e.g. during 2FA verification); all are essential. Local storage also keeps other display preferences (e.g. sidebar, command history) in your browser only. We use no analytics, advertising, or third-party tracking cookies. Essential cookies are required for the Service to work; you can delete any cookie in your browser settings.
5. Purposes and legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Running the account and Service (POS, rental, web order, booking, reports); technical support | (a), (b), (c) | Item b — performance of a contract |
| Security, audit, abuse prevention; backup and recovery | (a), (g), backup copies | Item f — legitimate interest; item c — legal obligation |
| The Merchant’s customer data | (d), (e), (f) | Set by the Merchant as Controller (usually the rental/order contract) |
| WhatsApp contact (opt-in) and rental customers’ ID card photos | (f) | Item a — explicit consent |
| Product improvement | Aggregated, non-identifying data | Item f — legitimate interest |
Never sold and never used for advertising. We do not perform profiling or automated decisions that have legal effects on you.
6. Storage location
VPS servers by Contabo in Singapore. If outside Indonesia, transfers follow UU PDP Article 56.
7. Who can access data
- The Merchant and staff according to their role. ID card photos can be uploaded and viewed by booking staff, but only the owner can delete them.
- Our team accesses data only to a limited extent, for support or incidents, at the Merchant’s request or for security needs.
- Platform admins have no customer-data screens, but server operators can technically access the server and are bound by confidentiality.
8. Sharing data with others
- Subprocessors: VPS provider Contabo; email provider dev@rasio.ai; DNS provider. App distribution via Google Play. Subprocessor changes are announced 14 days in advance.
- WhatsApp: messages to customers are opened manually from the Merchant’s own WhatsApp via a wa.me link. Our servers send no messages; WhatsApp’s policy applies to those messages.
- QRIS: We only store the Merchant’s static QRIS data to display it. Payment happens in the customer’s payment app; funds never pass through Us.
- Legal obligations: data is disclosed only under a valid legal order, limited to what is requested.
- We do not sell personal data.
9. Processing period and retention
| Data | Processing period | Retention (storage) |
|---|---|---|
| Account and business data | While the account is active | After leaving: 14-day export, deleted within 30 days |
| Sign-in sessions (IP, user agent) | 30 days since last activity; ends at sign-out | At most while the account is active; deleted with the account |
| Business audit log (IP, user agent) | While the account is active | Deleted with the business/account |
| Platform admin audit log (no names/emails) | When the admin action happens | Kept for accountability; no automatic deletion yet — period set before the final version |
| Paired POS devices | While the device is paired | Until the store is deleted |
| ID card photos | While the rental is ongoing | Until deleted by the Merchant; recommended 30 days after the rental ends |
| Daily server backups | — | 14 days; /files archives: last 7 automatic + 5 manual |
Data deleted in the app remains in backups until those backups expire.
10. Android POS app
- Internet: to sync with the store server.
- Bluetooth (nearby devices): only to find and print to receipt printers; scan results are never used to determine location.
- Location: requested only on Android 11 and below, because the system requires it for Bluetooth scanning. Your location is never read or stored.
- POS data is stored on the device so it keeps working offline, then synced to the store server.
11. Security
HTTPS; hashed passwords and PINs; 2FA for admins; ID card photos can only be opened by signed-in operators; national ID numbers and photo hashes are never logged; backup archives can only be downloaded by the owner (file mode 0600); audit log for admin actions; POS devices can be disconnected from the dashboard at any time.
12. Your rights and how to exercise them
- To be informed, to access, and to obtain a copy of your data;
- to correct inaccurate or incomplete data;
- to delete or destroy data;
- to withdraw consent (Article 9), without affecting earlier processing;
- to restrict or suspend processing;
- to obtain and transfer your data in a common machine-readable format (Article 13);
- to object to decisions based solely on automated processing, including profiling (Article 10) — we do not perform profiling or automated decisions;
- to sue and receive compensation for violations (Article 12).
How to apply: contact email dev@rasio.ai (support hours 24/7). We first verify your identity (e.g. via your account email) so data is never handed to someone else, then respond within 3×24 hours.
The Merchant’s customers apply to the Merchant. Requests that reach Us are forwarded to the Merchant within 3×24 hours, and We help the Merchant fulfil them within UU PDP limits (≤3×24 hours).
You also have the right to complain to the personal data protection authority.
13. Data protection failures
If a personal data protection failure occurs, We notify the Merchant within 24 hours of becoming aware of it: affected data, when and how it happened, and the response. The Merchant notifies data subjects and the authority within 3×24 hours (Article 46), with Our help.
14. Data protection contact
Privacy questions, rights requests, or complaints: email dev@rasio.ai (support hours 24/7). Operator: Rasio Labs, Seturan, Sleman, Yogyakarta, Sleman.
15. Children
The Service is meant for adult business owners and staff (18 and over), not for children. If a child’s data was entered anyway, We delete it at the request of a parent/guardian or the Merchant.
16. Change of ownership
If Dukuku by Rasio Labs, is merged, acquired, or transferred, We notify Merchants before and after personal data is transferred (Article 48). The recipient must follow this policy.
17. Changes to this policy
Changes are announced via WhatsApp/email 7 days before they take effect. The “Last updated” date above changes with them.
18. Language
This policy is available in Indonesian and English. If the versions differ in interpretation, the Indonesian version prevails (Presidential Regulation 63/2019 Article 26(4)).