1. GENERAL PROVISIONS

This privacy policy on personal data processing has been prepared in accordance with the requirements of applicable law and defines the procedure for processing personal data and the measures taken to ensure their security by PT. INTERNATIONAL MUSIC TEMPLE (hereinafter referred to as the Operator).

1.1. The Operator considers the protection of human and civil rights and freedoms when processing personal data, including the right to privacy, personal and family secrets, as its most important goal and condition for carrying out its activities.

1.2. This Policy applies to all information that the Operator may receive about visitors of the website https://moono.estate, as well as through the WhatsApp messenger, which users access via a link from the website.

2. KEY TERMS

2.1. Personal data — any information relating directly or indirectly to a specific or identifiable User.

2.2. Processing of personal data — any action or set of actions performed with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), use, transfer, depersonalization, blocking, deletion, and destruction of personal data.

2.3. User — any visitor of the website https://moono.estate and/or any person who has provided their personal data through the Operator’s WhatsApp chat.

2.4. WhatsApp — a third-party messaging service owned by Meta Platforms, through which the Operator may receive personal data. The WhatsApp privacy policy is available at: https://www.whatsapp.com/legal/privacy-policy.

2.5. Operator — PT. INTERNATIONAL MUSIC TEMPLE, independently or jointly with other parties organizing the processing of personal data, defining the purposes and scope of data, as well as the actions performed with them.

3. PRINCIPLES OF PERSONAL DATA PROCESSING

3.1. The processing of personal data is carried out on a lawful and fair basis.

3.2. The processing of data is limited to achieving specific, pre-defined, and legitimate purposes.

3.3. The Operator processes only the personal data that the User voluntarily provides when contacting the Operator via WhatsApp.

3.4. Personal data is stored in a form that allows identification of the data subject for no longer than required by the purposes of its processing, unless otherwise provided by law or by agreement.

4. TYPES OF DATA THAT MAY BE COLLECTED

The Operator may collect and process the following data if voluntarily provided by the User via WhatsApp chat:

• first and last name;

• phone number;

• email address;

• information required for consultation or booking real estate properties.

Technical information (such as cookies, IP addresses, and visit statistics) may be automatically collected on the website in an anonymized form and cannot be used to identify the User.

5. PURPOSES OF PERSONAL DATA PROCESSING

The Operator processes Users’ data for the following purposes:

• providing information about projects and real estate properties;

• arranging bookings and related services;

• communicating with clients and responding to their inquiries;

• conducting internal analytics and improving service quality.

6. CONDITIONS FOR DATA TRANSFER

6.1. Personal data is not transferred to third parties, except when necessary to fulfill the User’s request (e.g., payment services, booking systems) or as required by applicable law.

6.2. The transfer of data through WhatsApp is governed by WhatsApp’s own privacy policy, for which the Operator is not responsible.

7. USER RIGHTS

The User has the right to:

• receive information about the processing of their personal data;

• request clarification or deletion of their data;

8. STORAGE AND DATA PROTECTION

8.1. The Operator takes all necessary organizational and technical measures to protect personal data from unauthorized access, destruction, or modification.

8.2. Data is stored for as long as necessary to fulfill the purposes for which it was provided or until the User withdraws their consent.

9. USER CONSENT

9.1. By clicking the WhatsApp button on the website and submitting their data in the chat, the User confirms their consent to the processing of personal data in accordance with this Policy.

9.2. If the User does not agree with the terms of this Policy, they must refrain from using the website and providing data via WhatsApp.

10. FINAL PROVISIONS

10.1. The Operator reserves the right to amend this Policy. The current version is always available on the website at: https://moono.estate/privacy-policy-eng.