Subprocessors List

Legal & Privacy Center
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1. What This Page Covers

PT TURBULA AKAR INOVASI (“TurbulaAI”, “we”) uses a number of service providers, called subprocessors (prosesor data pribadi), to run our website, operate our early-access waitlist, and manage email communications. They process personal data only on our behalf, only on our instructions, and under written agreements that include personal data protection terms. This page lists them. How we handle personal data is explained in our Privacy Policy at legal.turbula.ai/privacy.

2. Current Subprocessors

SubprocessorCountry of establishmentPurposePersonal data involvedProcessing location
Cloudflare, Inc.United StatesHosting and delivery of the website (Cloudflare Pages), serverless waitlist API execution (Cloudflare Pages Functions), waitlist database storage (Cloudflare D1), and protection against bots and attacks (Cloudflare Turnstile and WAF)Website technical data (IP address, browser and device information, request logs, security challenge tokens) and waitlist records (first name, optional last name, email address, salted IP hash, submission timestamp, and Privacy Policy version record)Cloudflare’s global network, including outside Indonesia (such as the United States)
Plus Five Five, Inc. (Resend)United StatesTransactional email delivery for waitlist confirmation and early-access notificationsFirst name, optional last name, email address, and waitlist email content and delivery logsUnited States
Google LLC (Google Workspace)United StatesCorporate email communication, including [email protected]Contact data and the content of emailsGoogle’s global infrastructure, including outside Indonesia

3. Safeguards for Transfers Outside Indonesia

All current subprocessors are established outside Indonesia. We rely on the data processing agreements and security commitments in our contracts with them, in line with Article 56(3) of Law No. 27 of 2022 on Personal Data Protection. For users in the European Economic Area and the United Kingdom, these agreements include the European Commission’s Standard Contractual Clauses where required.

4. Changes to This List

We update this page when we add or replace a subprocessor and create a new dated version of this list.

5. Contact

Questions about our subprocessors can be sent to [email protected].