Privacy Policy

1.1. Personal Data is data about an identified or identifiable individual, whether directly or indirectly, through electronic or non-electronic systems, pursuant to Article 1 point 1 of Law Number 27 of 2022 concerning Personal Data Protection (“PDP Law”).

1.2. User is any person who creates an account and uses Certive services, whether as a Document Holder, Issuer, or Organization member.

1.3. Issuer is a User who issues Documents through Certive, either as an individual or on behalf of an Organization.

1.4. Document Holder is a User who receives and stores Documents issued to them.

1.5. Verifier is anyone who inspects the authenticity of a Document via a Certive verification link, with or without an active account.

1.6. Organization is an entity established within Certive to collectively issue Documents on behalf of an institution.

1.7. Document is any digital file issued by an Issuer through Certive to record its integrity and origin.

1.8. Digital Fingerprint (Hash) is a unique representation of the content of a Document, generated on the Issuer’s own device, recorded by Certive to prove Document integrity without ever storing the Document itself.

1.9. Registry Hash is Certive’s internal database that stores Digital Fingerprints of every Document ever issued, for duplication checking purposes.

1.10. Crypto Wallet is a blockchain-based digital wallet that can optionally be linked to a Certive account.

1.11. Personal Data Controller is the party determining the purposes and exercising control over the processing of Personal Data, in this case Baliola.

1.12. Personal Data Processor is a third party processing Personal Data on behalf of and under the instructions of the Personal Data Controller, as outlined in Section 4.

1.13. OpenCerts: An internationally recognized blockchain-based open-source framework standard initiated by GovTech Singapore for decentralized, tamper-proof issuance and verification of digital certificates.

1.14. Blockchain Identity (BID) & Decentralized Identifier (DID): Certive’s blockchain-based decentralized identity used to verify issuing entities (Issuers) or holders (Holders).

1.15. Verifiable Credentials (VC): Structured credential data files (.json) complying with W3C standards containing verified claims regarding document integrity, organization legitimacy, or membership.

1.16. Credential Payload: Data and metadata contained within a .json file.

1.17. Self-Sovereign Identity (SSI): The principle where Credential Holders personally hold, store, and control their digital credential files without relying on a centralized database.

2.1. Information you provide directly. When creating and using an account, We collect your name, email address, and password (stored encrypted, never in plain text). When establishing or managing an Organization, We collect institution name and invited member information. When undergoing Issuer eligibility review for notary and law firm segments, We may request professional registration numbers or business entity documents as governed in Article 4.3 of the Terms and Conditions.

2.2. Document-related information. We collect issuance metadata comprising Document type, brief description, recipient email address, and issuance time, along with the Digital Fingerprint of the Document. We never collect or store the contents or original files of Documents themselves. Each file is processed directly on the Issuer’s device to generate a Digital Fingerprint, and only derived values are transmitted to Certive. Document type and brief description fields are filled in directly by the Issuer; Certive does not review or moderate field contents, making the Issuer responsible for omitting specific Personal Data, such as health or children’s data, unless strictly necessary, aligned with the Issuer liability statement in Article 7.5 of the Terms and Conditions.

2.3. Payment information. For paid Service Plans, transactions are processed through third-party payment service providers. Certive does not store credit card numbers, debit card numbers, or payment instrument details directly on Our servers.

2.4. Crypto Wallet information. If you optionally link a Crypto Wallet, We only collect your public wallet address. Certive never requests, receives, or stores your Crypto Wallet private key.

2.5. Technical and log information. We collect IP addresses, device and browser types, authentication and login attempt logs, as well as Registry Hash access logs as governed in Article 13.6 of the Terms and Conditions, for security and audit trail purposes.

2.6. Information from Verifiers. For Verifiers logged in with an account, We collect conducted verification history. For Verifiers not logged in with an account, We collect only standard technical logs (such as IP address) required for system security, without additional personal identity data.

2.7. Google Drive Integration Data (OAuth Token) information. If an Organization enables cloud storage integration features (Google Drive), We collect and store authorization tokens (OAuth access tokens and refresh tokens) with limited scope access rights. These tokens are used specifically to upload and store stamped document files into folders designated by the Organization. Certive never reads, accesses, modifies, or stores files or other personal data stored in your Google Drive account outside the dedicated integrated folder.

2.8. PDF Certificate Metadata & Public Verify Data information. For generating Certificates of Document Integrity and rendering public verification pages (Public Verify), We collect and process technical metadata and official issuer profile data. This data includes:

• Document Metadata: File name, document number, document version (v1, v2, etc.), stamping mode (Stamping Mode), file size, description, as well as official timestamp of approval (Stamped At).
• Issuer & Organization Identity: Issuer name, responsible party email address, organization name, website, and digital wallet address (wallet address) of issuer and organization.
• Organization Physical Location Data: Official domicile information of the organization including country (Country), province (State), city (City), postal code (Postal Code), and full address (Address).

All metadata above is processed and displayed publicly on PDF certificate sheets as well as public verification browsers to provide proof of integrity and origin transparency.

2.9. Verifiable Credentials Payload Data: When an Issuer issues Verifiable Credentials (such as Certificate of Document Integrity, Organization Verification, or Membership Credential), personal data entered into the payload (such as member name, email, role/title, or document metadata) is processed locally on the user’s browser side (Zero Storage) and formed into a digital credential file. Certive does not store raw copies (.json) in Our centralized database. Credential files are handed over and held independently by the Document Holder (Self-Sovereign Identity).

2.10. Decentralized Identity Data (BID/DID): We collect and process decentralized identifier addresses (did:bid:...), public keys, and wallet addresses of organizations or users for cryptographic identity resolution during credential issuance and verification.

3.1. We use collected information to provide and operate Certive’s core services, including Document issuance, verification, and revocation.

3.2. We use email addresses to verify account identity, send issuance notifications and Verification Links, and secure your account.

3.3. We use supporting documents submitted by you to perform Issuer eligibility reviews and determine Issuer Trust Levels as governed in Article 9 of the Terms and Conditions.

3.4. We use Digital Fingerprints and issuance metadata to prevent duplication, detect misuse indications, and follow up on reports as governed in Article 11 of the Terms and Conditions.

3.5. We use payment information to process Service Plan and Web3 Staking program billing.

3.6. We use collected information to fulfill legal obligations, including compliance with PDP Law and official requests from competent authorities.

3.7. We use aggregated usage data to enhance the quality, reliability, and security of Certive services.

3.8. We may send marketing communications regarding Baliola products and services. These communications are optional, and you may unsubscribe at any time via links in every email.

4.1. Certive does not sell your Personal Data to any party.

4.2. Mandala Chain. Digital Fingerprints, in the form of secret-key derived values as governed in Article 13.3 of the Terms and Conditions, are permanently recorded onto the partner blockchain network. These records contain no Personal Data or Document content, but are public and permanent on the blockchain network and cannot be deleted by anyone, including Baliola, once successfully recorded. Erasure rights implications are further detailed in Section 6.5.

4.3. Third-party service providers. We share relevant information with payment service providers, email delivery services, key management services (Key Management Service), and cloud infrastructure providers as Personal Data Processors acting under Our instructions and bound by confidentiality obligations.

4.4. Document Recipients. When an Issuer issues a Document, specified recipient email addresses are used to send notifications and Verification Links, as an inherent part of the issuance service.

4.5. Competent authorities. We may disclose information if required by law, court order, or other lawful legal processes.

4.6. Business transactions. In the event of a reorganization, merger, acquisition, or sale of Baliola’s business, your information may be transferred to successor entities as governed in Article 23.4 of the Terms and Conditions, with notice to affected Users.

4.7. Third-Party Cloud Storage Providers. If an Organization enables Google Drive integration features, stamped original document files will be sent automatically to the connected Organization-owned storage account. In this case, cloud storage service providers (Google Drive / Google Workspace) act as Third-Party Data Processors managing files under instructions, terms, and full control of the User Organization, not under independent control of Certive.

4.8. Technical and Operational Separation of Google SSO and Organization Google Drive Data Processing. We technically and operationally separate individual authentication data processing from organization storage integration data:

• Google SSO authorization data (in Personal Account menu) is used solely to verify individual User login identity.
• Google Drive authorization data (in Organization Settings menu) is used solely for organization document file delivery. Authorization permission from either feature is never used to grant access or trigger actions in the other feature.

4.9. On-Chain Data on Mandala Chain: Data recorded onto the Mandala Chain blockchain consists solely of cryptographic values (Cryptographic Hash / Merkle Root), Issuer Decentralized Identity (BID/DID), and Validity Status (Active/Revoked). These records contain no Sensitive Personal Data (Personally Identifiable Information - PII) in raw text. On-chain records are public, permanent, and immutable.

4.10. Global Verification Portal Interoperability: When a Verifier verifies .json files through Certive’s public portal or global OpenCerts portal opencerts.io, hash matching and BID status checking occur directly client-side in the browser against blockchain smart contract records. No raw personal data is transmitted to centralized servers during this verification process.

5.1. All data communication between User devices and Certive systems is encrypted, and passwords and sensitive data are stored using industry-standard encryption.

5.2. Digital Fingerprints are generated directly on the Issuer’s own device. Original Document files are never transmitted to or stored on Certive servers, a privacy commitment designed from the product design stage (privacy by design).

5.3. Secret keys used to derive final hash values are stored in managed key management services (Key Management Service), never embedded directly in code, and support periodic rotation with version tracking.

5.4. Access to the Hash Registry is restricted internally, and all access is logged as part of Baliola’s security audit trail.

5.5. Certive temporarily restricts repeated failed login attempts, and login sessions automatically expire after a set period to prevent unauthorized access.

5.6. We continuously evaluate and update information security practices in line with evolving threats and industry standards.

5.7. Data protection breach notification. In the event of a Personal Data Protection breach affecting the confidentiality, integrity, or availability of your Personal Data, Baliola will issue written notice to you no later than 3 (three) calendar days (3x24 hours) from discovery of such failure, pursuant to Article 46 of the PDP Law, along with handling and recovery measures undertaken or planned. Under certain circumstances significantly impacting public services or public interest, general public notice will also be provided.

According to Law Number 27 of 2022 concerning Personal Data Protection, you possess the following rights over your Personal Data.

6.1. Right to be informed regarding clear identity, legal basis of interest, purpose of request and use, and accountability of parties requesting your Personal Data.

6.2. Right to access and obtain copies of Personal Data We store about you.

6.3. Right to complete, update, and/or rectify errors and/or inaccuracies in your Personal Data. We will follow up on this request no later than 3 (three) calendar days from receipt of a complete application, pursuant to Article 30 of the PDP Law.

6.4. Right to delay and restrict processing of your Personal Data in whole or in part. We will follow up on this request no later than 3 (three) calendar days from receipt of request, pursuant to Article 41 of the PDP Law.

6.5. Right to terminate processing, erase, and/or destroy your Personal Data, with one important exception to understand: Digital Fingerprints permanently logged on the blockchain cannot be deleted by anyone, including Baliola, due to the tamper-proof nature of blockchain networks. These records contain no Personal Data or Document content. Account data, issuance metadata, and other personal information stored in internal Certive systems can be deleted or anonymized upon request, except parts required for legal compliance.

6.6. Right to withdraw consent previously granted for Personal Data processing, provided such withdrawal does not conflict with statutory provisions.

6.7. Right to object to automated decision-making processes, including profiling, producing legal effects or significantly affecting you.

6.8. Right to data portability, namely obtaining and using your Personal Data in commonly used, machine-readable format, and transferring it to another Personal Data Controller, where technically feasible.

6.9. Right to sue and receive compensation for Personal Data processing violations affecting you in accordance with laws and regulations.

6.10. Right to lodge a complaint with the Personal Data Protection supervisory agency mandated by Article 58 of the PDP Law. As of the date of this Privacy Policy update, such agency has not been officially established by the Government of the Republic of Indonesia. Pending agency operation, sector-specific PDP compliance complaints may be submitted to the Ministry of Communication and Digital, without prejudice to your right to complain to the supervisory agency once officially operational.

6.11. You may exercise the above rights by contacting Us via channels in Section 10. For requests without fixed statutory deadlines under the PDP Law, We will respond within a reasonable timeframe.

7.1. Certive uses essential cookies necessary to maintain your login session and support security features, including restricting failed login attempts.

7.2. Certive may use analytics cookies to understand aggregated platform usage patterns to improve service quality.

7.3. You may configure or decline non-essential cookies through browser settings. Declining essential cookies may disrupt login functionality and account security.

7.4. Certive does not use third-party cookies for advertising purposes.

8.1. Your account data is stored while your account remains active, and for a specified period following account closure to meet legal, audit, or dispute resolution requirements.

8.2. Issuance metadata and Digital Fingerprints in the Hash Registry are stored as long as the relevant Document remains actively recorded on the blockchain, required as reference for duplicate checking and ongoing verification as governed in Article 7.4 of the Terms and Conditions.

8.3. Digital Fingerprints logged on the blockchain network are permanent and have no retention period, as they cannot be deleted by anyone once recorded, including Baliola itself.

8.4. Payment data is stored for statutory periods required under applicable Indonesian tax and accounting laws.

8.5. Retention and Visibility of PDF Certificates of Document Integrity. PDF Certificates of Document Integrity and verification metadata are stored in Our system as long as the relevant Document remains active. Public access to certificate files and verification sheets is subject to the following document visibility mechanisms:

• Unpublish: If a Document status is changed to Unpublish, PDF certificate files and public verification pages are hidden from public access, but underlying hash records on the blockchain remain permanently stored.
• Revoke: If a Document is revoked (Revoked), certificates and verification pages permanently display revocation status labels alongside official reasons.
• Account Closure: If an Organization account is closed, access to download new PDF certificates will be terminated, while hash records published on the blockchain network remain permanently stored and cannot be deleted.

8.6. Retention & Visibility Status of Verifiable Credentials:

• Unpublish: Changes document/certificate visibility so it does not appear on public Certive verification browsers without deleting underlying blockchain hash records.
• Revoke: Permanently changes smart contract status on the blockchain to REVOKED. OpenCerts verification portals worldwide will automatically display revocation status along with official reasons.
• Account Closure: Off-chain personal account data will be deleted/anonymized, while blockchain hash validity and revocation status records remain permanently stored to maintain public verification history integrity.

8.7. Following account closure, Personal Data no longer required will be erased or anonymized, except parts required for legal compliance as governed in Section 6.5.

9.1. Baliola reserves the right to update this Privacy Policy from time to time to reflect changes in services, technology, or applicable legal provisions, including evolving PDP Law implementing regulations and supervisory agency establishment.

9.2. Material changes will be notified to Users via registered email or in-platform notifications at least seven calendar days prior to taking effect, aligned with Article 21.2 of the Terms and Conditions.

9.3. Continued use of Certive services following the effective date of changes constitutes acceptance of the updated Privacy Policy.

10.1. Any questions, requests to exercise Personal Data rights, or privacy-related complaints may be submitted via email: support@baliola.io.

10.2. Baliola will respond to incoming requests within timeframes governed in Section 6, or within a reasonable timeframe for requests lacking fixed statutory deadlines under the PDP Law.

Still have questions about your privacy? Our Team is ready to help you understand how Certive protects your data. Contact Us at support@baliola.io.