Privacy Policy
Effective Date: 21 October 2026
Last Updated: 21 October 2026
1. Introduction
Mirah Investment & Development (“Mirah”, “we”, “us”, or “our”) is committed to protecting the privacy and personal information of individuals who interact with our business.
This Privacy Policy explains how we collect, use, process, store, disclose, transfer, and protect personal information in connection with our website, property developments, investment-related enquiries, marketing activities, and other business communications.
The Website at https://mirahdevelopments.com/ is operated by PT Mirah Global Investment, an Indonesian company operating under the Mirah Investment & Development brand.
Company Information
PT Mirah Global Investment
Trading as Mirah Investment & Development
Contact Address:
Jl. Raya Anyar No.24, Kerobokan,
Kec. Kuta Utara, Kabupaten Badung,
Bali 80361, Indonesia
Email: [email protected]
Telephone: +62 85 100 800 800
Website: https://mirahdevelopments.com/
We process personal information in accordance with applicable data protection legislation, including Indonesia’s Law No. 27 of 2022 concerning Personal Data Protection (UU PDP), its applicable implementing regulations, and other laws that may apply to particular processing activities or individuals.
Where relevant, we also take account of applicable international privacy and marketing requirements.
This Privacy Policy should be read together with our Terms & Conditions:
https://mirahdevelopments.com/terms-conditions/
2. Scope of This Privacy Policy
This Privacy Policy applies to personal information collected or processed by Mirah through the following channels, where this Policy is provided or referenced:
- Our Website and associated enquiry forms.
- Property registration and information-request forms.
- Website landing pages and marketing campaigns.
- Meta (Facebook and Instagram) Lead Ads.
- Email and newsletter subscriptions.
- SMS communications.
- Telephone calls and messaging services.
- WhatsApp and social media interactions.
- Online and in-person property consultations.
- Property exhibitions, presentations, and promotional events.
- Customer relationship management (CRM) activities.
- Recruitment enquiries and job applications.
This Policy also applies where we receive personal information from authorized representatives, introducers, referral partners, or other sources in accordance with applicable law.
Individual property transactions or services may involve separate legal entities, including project-specific development companies, affiliated businesses, and third-party operators.
Where another legal entity acts as an independent or joint personal data controller, the relevant responsibilities and any additional privacy information will be communicated as required by law.
Third-party websites or services that operate independently may be subject to their own privacy policies.
3. Personal Information We Collect
Depending on how you interact with us, we may collect and process the following categories of personal information.
3.1 Personal Identification and Contact Information
This may include:
- First name and last name.
- Email address.
- Mobile and telephone numbers.
- Country of residence.
- Nationality, where relevant and lawfully required.
- Postal or business address.
- Company name and job title.
- Preferred language and communication method.
3.2 Property Enquiry and Investment Preferences
When you enquire about a property or investment opportunity, we may collect information relating to:
- Properties or developments of interest.
- Preferred property types and locations.
- Indicative investment budgets or price preferences.
- Preferred purchase or payment arrangements.
- Intended property use or investment objectives.
- Consultation and appointment requests.
- Relevant questions, comments, and correspondence.
- Enquiry history and customer service interactions.
We use this information to understand your enquiry, provide relevant information, and assist you with your requested services.
3.3 Marketing and Communication Information
We may collect:
- Email and telephone communication preferences.
- Newsletter subscription status.
- SMS opt-in and opt-out preferences.
- Records of marketing consent.
- Dates and times of consent or withdrawal.
- Registration channels and campaign sources.
- Records of communications with our representatives.
- Campaign interactions, including email opens and clicks where legally permitted.
3.4 Website and Technical Information
When you access our Website, certain technical information may be collected automatically, including:
- IP address.
- Browser type and version.
- Device and operating system information.
- Approximate geographic location derived from technical information.
- Pages visited and time spent on the Website.
- Referring websites and traffic sources.
- Advertising campaign identifiers and UTM parameters.
- Cookie identifiers and similar online identifiers.
- Website interactions and conversion events.
Information collected through cookies and similar technologies is further explained in Section 10.
3.5 Transaction and Verification Information
Where you proceed with a property transaction or another service requiring additional verification, we or the relevant contracting entity may collect information necessary for contractual, administrative, regulatory, or compliance purposes.
Depending on the transaction, this may include identification documents, billing information, payment records, tax information, proof of authority, and other documents required by applicable law.
Such information should be provided only through authorized and appropriately secured channels.
3.6 Recruitment Information
If you apply for employment with Mirah, we may collect information including your name, contact details, curriculum vitae, professional qualifications, employment history, portfolio, and other information relevant to the recruitment process.
3.7 Sensitive Personal Information
We do not generally require sensitive personal information for ordinary website enquiries.
Where sensitive or specifically protected personal information is necessary for a particular transaction, verification process, or legal obligation, we will process it only where permitted by applicable law and with appropriate safeguards.
We encourage users not to submit unnecessary sensitive information through general website forms.
4. How We Collect Personal Information
We may collect information directly from you when you:
- Complete a website enquiry or registration form.
- Request a property brochure or presentation.
- Subscribe to marketing communications.
- Register through a Meta Lead Ads form.
- Book a consultation or meeting.
- Contact our representatives by telephone, email, WhatsApp, or SMS.
- Attend an exhibition, presentation, or promotional event.
- Enter into a reservation or other contractual process.
- Apply for a position with Mirah.
We may also receive information from authorized business partners, property introducers, referral sources, advertising platforms, and service providers where the collection and transfer of that information are lawful.
Where personal information is obtained indirectly, we will process it only for appropriate purposes and in accordance with applicable notification and consent requirements.
We do not treat the purchase or receipt of a third-party contact list as evidence that its individuals have consented to receive promotional SMS messages from Mirah.
5. Purposes and Legal Bases for Processing
We collect and process personal information only where we have an appropriate legal basis and a defined purpose.
Depending on the circumstances, processing may be based on your consent, steps taken at your request before entering into a contract, performance of a contract, compliance with legal obligations, or legitimate interests where permitted by law and balanced against your rights.
5.1 Responding to Enquiries
We use contact details and enquiry information to:
- Respond to questions.
- Provide requested property information.
- Send brochures and presentations.
- Arrange consultations.
- Follow up on active enquiries.
- Provide customer assistance.
5.2 Property Transactions and Client Services
Where relevant, we process information to:
- Support reservations and contractual arrangements.
- Perform identity and eligibility checks.
- Prepare transaction documents.
- Coordinate with authorized professional advisers.
- Administer payment and transaction records.
- Fulfil applicable legal and regulatory obligations.
5.3 Marketing Communications
Where we have the required permission or another lawful basis, we may use personal information to communicate about:
- New property developments.
- Property launches and availability.
- Events, presentations, and investment-related opportunities.
- Promotional offers and incentives.
- Company news and relevant updates.
Marketing communications are subject to applicable consent, disclosure, and opt-out requirements.
5.4 Business Operations and Service Improvement
We may process information to:
- Maintain customer records.
- Manage and prioritize enquiries.
- Improve customer service.
- Measure campaign and website performance.
- Analyze aggregated business and marketing trends.
- Maintain internal administrative records.
- Protect our systems and prevent misuse.
5.5 Legal and Regulatory Compliance
We may process information where necessary to comply with applicable laws, respond to lawful requests, maintain required records, investigate suspected fraud, or establish, exercise, or defend legal claims.
Where processing is based on consent, you may withdraw that consent in accordance with applicable law.
Withdrawal does not affect processing lawfully carried out before the withdrawal.
6. Marketing Communications and Your Choices
We may contact individuals through email, telephone, WhatsApp, SMS, or other communication channels for purposes permitted by law.
We distinguish between communications relating to a specific enquiry or requested service and promotional communications.
6.1 Enquiry-Related Communications
When you contact Mirah or request information, we may use the contact details you provide to respond to your request and manage the related enquiry, subject to applicable law.
Providing your telephone number does not automatically authorize recurring promotional SMS messages or automated marketing calls.
6.2 Promotional Communications
Where required by law, we obtain separate consent before sending promotional communications.
Your preferences may be recorded in our customer relationship management systems.
Consent for one communication channel does not automatically constitute consent for all other channels.
6.3 Withdrawing Marketing Consent
You may unsubscribe from promotional emails by using the unsubscribe link included in eligible marketing emails.
You may opt out of SMS messages by replying STOP to an SMS received from the relevant program.
You may also request changes to your communication preferences by contacting:
We will process valid opt-out requests in accordance with applicable laws and relevant communication-channel requirements.
We may retain limited information necessary to record and respect your preferences and prevent unwanted communications.
7. SMS Communications and Mobile Data Privacy
Mirah operates an SMS messaging program under the name:
Mirah Investment & Development SMS Communications
This section explains how mobile information and SMS consent data are processed.
7.1 SMS Program Description
Individuals who have provided the required consent may receive SMS communications relating to:
- Property enquiries.
- Requested property information.
- Consultation scheduling.
- Appointment confirmations and reminders.
- Relevant customer service follow-ups.
Individuals who separately consent to marketing SMS may also receive information about:
- New property developments and launches.
- Property availability.
- Promotional offers.
- Invitations to events and presentations.
- Other Mirah property-related marketing communications.
7.2 SMS Opt-In
SMS consent may be collected through authorized website forms, Meta (Facebook and Instagram) Lead Ads forms, and other designated registration channels that provide appropriate disclosures.
Where SMS consent is requested through an online form, the relevant opt-in must be obtained through an appropriate affirmative action.
Consent to receive marketing SMS is obtained separately from any consent required for enquiry-related or appointment-related messages.
Submitting a general enquiry, entering a telephone number, or accepting the Website Terms & Conditions does not automatically constitute consent to receive promotional SMS messages.
Consent to receive SMS messages is not a condition of purchasing any property, product, or service.
7.3 SMS Message Frequency and Charges
Message frequency varies depending on the individual’s interactions, enquiry activity, subscriptions, and communication preferences.
Message and data rates may apply.
Charges imposed by a mobile network provider are determined by the individual’s mobile service agreement.
7.4 SMS Opt-Out
Reply STOP to any SMS message from the program to unsubscribe.
After a valid unsubscribe request, you may receive a final confirmation message.
You will not receive further messages under the unsubscribed program unless you subsequently provide new consent or a message is otherwise required or permitted by law.
You may also contact [email protected] for assistance.
7.5 SMS Customer Support
Reply HELP to an SMS message for assistance.
You may also contact us at:
7.6 Mobile Information and Consent Sharing
No mobile information will be shared with third parties or affiliates for their own marketing or promotional purposes.
We do not sell, rent, or provide mobile phone numbers or SMS opt-in information to third parties, affiliates, or lead generators for their independent marketing activities.
All other categories of data sharing described in this Privacy Policy exclude text messaging originator opt-in data and consent for third-party marketing or promotional use. Such SMS opt-in data and consent will not be transferred or shared with third parties for those purposes.
We may disclose information necessary to operate the SMS program to contracted telecommunications carriers, messaging aggregators, and technical service providers acting on our instructions solely to deliver, process, and support our SMS communications.
These service providers are not authorized to use SMS subscriber information for their own independent marketing.
SMS marketing consent is specific to the relevant sending business and messaging program. It is not automatically transferable to another business or marketing sender.
7.7 SMS Consent Records
For compliance and record-keeping purposes, we may maintain records showing how and when SMS consent was obtained.
These records may include:
- Mobile number.
- Consent status and preferences.
- Date and time of opt-in.
- Registration source or form.
- Version or wording of the consent disclosure.
- Relevant technical records, where lawfully collected.
- Date and method of withdrawal or opt-out.
Such records are used to demonstrate compliance, manage communication preferences, and prevent messages being sent without the appropriate authorization.
7.8 SMS Delivery and Security
SMS delivery depends on telecommunications networks and service providers.
Carriers are not liable for delayed or undelivered messages.
SMS is not a guaranteed secure communication method, and users should avoid transmitting passwords, payment card details, or other sensitive information through ordinary text messages.
Additional SMS program conditions are available in our Terms & Conditions:
https://mirahdevelopments.com/terms-conditions/
8. Telephone Calls, WhatsApp, and Social Media
We may communicate with you using your preferred contact method when appropriate and legally permitted.
8.1 Telephone Communications
Telephone calls may be used to respond to enquiries, arrange appointments, provide requested assistance, and conduct other lawful business communications.
Where call recording or monitoring is used, appropriate notices or consent will be provided as required by applicable law.
Recordings may be processed for quality assurance, staff training, dispute resolution, and compliance purposes.
Where automated dialing technology or automated marketing calls are used, additional consent and regulatory requirements may apply.
Consent to receive SMS messages does not automatically authorize automated marketing telephone calls.
8.2 WhatsApp and Messaging Applications
When you communicate with Mirah through WhatsApp or another messaging application, relevant contact information and message content may be processed to respond to your enquiry.
The messaging platform may independently process information under its own privacy policy and applicable terms.
8.3 Social Media
When you interact with our social media accounts, we may receive information provided through comments, direct messages, enquiry forms, and other platform features.
The platform operator may independently collect and process information according to its own privacy practices.
9. Meta Lead Ads and Online Advertising Forms
Mirah may use Meta advertising services, including Facebook and Instagram Lead Ads, to collect expressions of interest, property enquiries, and consultation requests.
When you submit a Meta Lead Ads form, the information you provide may be transferred to Mirah for the purposes identified in the form and this Privacy Policy.
This may include your name, email address, telephone number, selected property interests, and responses to form questions.
Where optional marketing communications require consent, the relevant permission must be obtained through the appropriate consent mechanism.
Consent to receive promotional SMS messages is not inferred solely from the submission of a Meta Lead Ads form.
Lead information may be transferred into our CRM systems and processed by authorized personnel for appropriate sales and customer service activities.
Meta may independently process information collected through its platforms in accordance with its own policies.
10. Cookies, Analytics, and Advertising Technologies
Our Website may use cookies, pixels, tags, and similar technologies to operate the Website, analyze user activity, improve our services, and measure marketing performance.
10.1 Essential Cookies
These support basic Website functionality, security, navigation, and other features necessary for the operation of the Website.
10.2 Analytics Cookies
Analytics technologies may help us understand:
- Website traffic.
- Popular pages.
- Visitor interactions.
- Navigation patterns.
- Website performance.
- Sources of enquiries and conversions.
Information may be aggregated or analyzed to improve the Website and user experience.
10.3 Advertising and Marketing Technologies
Where deployed, our Website may use services provided by advertising and analytics platforms, including Google, Meta, and LinkedIn.
These technologies may support:
- Measuring advertising conversions.
- Evaluating campaign performance.
- Understanding interactions with advertisements.
- Building or evaluating advertising audiences where legally permitted.
- Delivering relevant advertising subject to applicable consent and privacy requirements.
Relevant technologies may include Google Tag Manager, Google Analytics, Google Ads conversion tracking, Meta Pixel, and LinkedIn advertising or analytics tags.
The technologies actually used may change over time.
Third-party advertising platforms may process certain technical or interaction data under their own privacy policies and applicable agreements.
We do not disclose SMS opt-in consent records to advertising platforms for their independent marketing activities.
10.4 Cookie Preferences
Where required by applicable law, we will request appropriate consent before activating non-essential cookies or tracking technologies.
You may be able to manage cookie preferences through consent controls provided on the Website.
You may also adjust cookie settings through your browser.
Disabling certain cookies may affect Website functionality or the availability of some features.
11. Customer Relationship Management and Automated Processing
Mirah may use customer relationship management, sales automation, communications, and marketing platforms to organize and manage enquiries.
Such systems may be used to:
- Maintain contact records.
- Track enquiry status.
- Assign enquiries to appropriate team members.
- Schedule follow-up activities.
- Record communication history.
- Manage communication preferences.
- Analyze sales and marketing performance.
- Identify relevant properties based on stated preferences.
These activities may involve automated categorization, lead prioritization, or segmentation.
Where automated systems are used to assist internal operations, they do not, by themselves, determine an individual’s legal entitlement to property ownership or establish contractual obligations.
Where applicable law provides rights relating to automated decision-making or profiling, those rights will be respected.
12. Disclosure of Personal Information
We may disclose personal information only where there is an appropriate legal basis and a legitimate purpose.
Depending on the circumstances, recipients may include:
12.1 Authorized Personnel
Employees, sales representatives, and other authorized personnel who require access to perform their responsibilities.
Access should be limited according to relevant job functions and business requirements.
12.2 Contracted Service Providers
We may engage service providers to support:
- Website hosting and maintenance.
- CRM administration.
- Cloud storage and information technology.
- Email and SMS delivery.
- Telephone and customer communication services.
- Marketing operations and analytics.
- Customer support and appointment scheduling.
- Data security and technical administration.
Depending on the services used, these may include platforms such as Salesforce, CloudTalk, Mailchimp, Meta, Google, and other authorized technology providers.
Service providers processing information on our behalf are expected to handle it only for authorized purposes and subject to applicable contractual and legal safeguards.
12.3 Project-Specific Entities and Professional Advisers
Where necessary for a requested transaction or service, relevant information may be disclosed to authorized project companies, legal advisers, notaries, accountants, or other parties involved in the transaction.
Where a recipient is an independent data controller, its separate responsibilities and any additional privacy information will apply.
12.4 Legal and Regulatory Authorities
We may disclose information where required by law, valid legal process, or lawful requests from authorized public authorities.
12.5 Business Transfers
In connection with a lawful merger, restructuring, acquisition, or transfer of relevant business operations, information may be transferred where permitted by law and subject to appropriate notification and protection requirements.
12.6 No Unauthorized Sale or Marketing Disclosure
We do not sell or rent personal information as a business practice.
Personal information will not be disclosed to unrelated third parties for their independent direct marketing without an appropriate lawful basis and, where required, your specific consent.
The stricter protections relating to mobile information and SMS consent described in Section 7.6 apply regardless of other disclosure provisions.
13. International Data Transfers
Mirah operates in Indonesia and may use technology platforms, cloud services, and business service providers located in other countries.
As a result, personal information may be transferred, stored, accessed, or otherwise processed outside Indonesia.
These transfers may occur when using international CRM, cloud hosting, communications, analytics, or marketing technology services.
Where international transfers take place, we will apply the requirements of applicable personal data protection laws.
Depending on the legal circumstances, this may involve assessing the level of protection in the destination jurisdiction, implementing appropriate contractual or other safeguards, or obtaining specific consent where legally required.
We will take reasonable steps to ensure that international transfers are limited to appropriate purposes and that personal information receives the protections required by applicable law.
International transfers do not authorize service providers to use SMS opt-in data for their independent marketing purposes.
14. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including applicable legal, contractual, administrative, and compliance requirements.
Our retention approach distinguishes between different categories of information.
14.1 Enquiries and Prospective Customer Records
Enquiry and CRM information may be retained while a relevant enquiry or customer relationship remains active.
For inactive prospective customer records, our proposed standard retention period is up to 36 months following the last meaningful interaction, unless an earlier deletion request applies or another lawful basis requires continued retention.
14.2 Marketing Subscriptions and Consent Records
Marketing contact information may be retained while a subscription or other lawful basis for the relevant communication remains active.
Following withdrawal, we may retain limited opt-out and consent records for up to five years, where reasonably necessary for compliance, record-keeping, dispute resolution, or the prevention of unwanted communications.
14.3 Transaction and Contractual Records
Where personal information forms part of a property transaction or other contractual relationship, relevant records may be retained for the duration of the relationship and for up to ten years afterwards, or for a longer period where required or justified by applicable law, legal proceedings, or continuing obligations.
14.4 Recruitment Information
Information relating to unsuccessful job applications may ordinarily be retained for up to 12 months after the recruitment decision, unless the applicant has agreed to longer retention or another lawful reason applies.
14.5 Technical and Website Data
Technical logs and website usage records are retained according to their operational purpose, applicable security requirements, and the settings of the relevant systems.
Cookie retention periods may vary depending on the particular cookie or technology.
14.6 Deletion and Anonymization
When personal information is no longer required and no lawful retention obligation remains, we will take appropriate steps to delete, destroy, or anonymize it.
Where a valid deletion request is received, it will be assessed and processed in accordance with applicable legal requirements.
15. Information Security
We take reasonable technical, organizational, and administrative measures designed to protect personal information against unauthorized access, disclosure, alteration, loss, destruction, and misuse.
These measures may include appropriate access restrictions, authentication, system monitoring, staff procedures, and security controls proportionate to the risks involved.
Access to personal information should be limited to authorized individuals and service providers who require it for legitimate purposes.
We also seek appropriate confidentiality and data protection commitments from contracted service providers.
No method of electronic transmission, internet communication, or digital storage can be guaranteed to be completely secure.
Users should take appropriate precautions when submitting information online and should report suspected fraudulent communications or security concerns through our official contact channels.
16. Your Privacy Rights
Depending on applicable law and your circumstances, you may have rights concerning your personal information, including the right to:
- Obtain information about how your personal data is processed.
- Request access to personal information held about you.
- Request correction of inaccurate or incomplete information.
- Withdraw consent where processing is based on consent.
- Request deletion or destruction of personal information where legally applicable.
- Request restrictions or suspension of certain processing activities.
- Object to particular processing activities where the law provides that right.
- Exercise applicable rights concerning automated decision-making.
- Request data portability where provided by applicable law.
- Submit complaints or pursue other remedies available under relevant legislation.
Some rights are subject to legal conditions or exceptions, including situations involving contractual obligations, legal record-keeping, fraud prevention, or the rights of other individuals.
16.1 Submitting a Privacy Request
To exercise an applicable privacy right, please contact:
Please include sufficient information to identify yourself and explain your request.
We may request reasonable verification before disclosing, correcting, or deleting personal information.
We will process requests within the timeframes required by applicable law.
We do not impose fees for exercising privacy rights where prohibited by law.
16.2 Withdrawal of Consent
You may withdraw consent at any time where consent is the applicable basis for processing.
Withdrawal does not invalidate processing lawfully performed before the withdrawal.
In some circumstances, we may continue to retain limited information where another lawful basis or legal obligation applies.
16.3 International Privacy Rights
Individuals in jurisdictions with additional privacy protections may have further rights under applicable local legislation.
Where such laws apply to Mirah’s processing activities, we will assess and respond to requests in accordance with those requirements.
This may include relevant provisions of European, United Kingdom, United States, or other applicable data protection laws.
17. Children and Minors
Our Website and property investment services are primarily intended for adults.
We do not knowingly solicit personal information from children for property investment marketing purposes.
Where personal information concerning a minor must be processed for a lawful purpose, we will apply the relevant legal requirements, including any necessary consent from a parent or legal guardian.
If you believe that personal information concerning a child has been collected or processed inappropriately, please contact us.
18. Third-Party Websites and External Platforms
Our Website may contain links to websites, social media platforms, payment services, or other online resources operated by third parties.
Such platforms may collect and process personal information independently.
Mirah does not control the privacy practices of independent third-party websites.
We encourage users to review the privacy policies of external services before providing personal information through them.
This provision does not limit responsibilities that Mirah may have under applicable law when selecting or engaging third-party processors.
19. Personal Data Incidents
We maintain procedures intended to identify, assess, and respond to suspected or confirmed incidents affecting the security of personal information.
Where a personal data protection incident triggers notification requirements under applicable law, we will notify affected individuals and relevant authorities within the legally required timeframes and provide the information required by law.
We may also take appropriate steps to investigate the incident, mitigate risks, and improve relevant safeguards.
20. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in legislation, business practices, technology, services, or personal information processing activities.
Updates will be published on this page with a revised “Last Updated” date.
Where a material change requires additional notice or renewed consent, we will take the steps required by applicable law before implementing the relevant processing change.
Continued use of the Website does not replace any specific consent required for a new processing purpose.
21. Contact Us
If you have questions about this Privacy Policy, the processing of your personal information, your communication preferences, or your rights, please contact:
PT Mirah Global Investment
Mirah Investment & Development
Address:
Jl. Raya Anyar No.24, Kerobokan,
Kec. Kuta Utara, Kabupaten Badung,
Bali 80361, Indonesia
Email: [email protected]
Telephone: +62 85 100 800 800
Website: https://mirahdevelopments.com/
For information about the general use of our Website, please review:
Terms & Conditions:
https://mirahdevelopments.com/terms-conditions/
© 2026 PT Mirah Global Investment. All rights reserved.