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
| Subprocessor | Country of establishment | Purpose | Personal data involved | Processing location |
|---|---|---|---|---|
| Cloudflare, Inc. | United States | Hosting 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 States | Transactional email delivery for waitlist confirmation and early-access notifications | First name, optional last name, email address, and waitlist email content and delivery logs | United States |
| Google LLC (Google Workspace) | United States | Corporate email communication, including [email protected] | Contact data and the content of emails | Google’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].