Privacy Policy

menurutlo is committed to protecting your privacy. This policy explains what data we collect, how we use it, and your rights regarding your personal information. We comply with Indonesia's Personal Data Protection Law (UU PDP No. 27/2022) and its implementing regulations including PP TUNAS and Permenkomdigi 9/2026.

1. Who We Are

menurutlo is operated by PT. Kreasi Lintas Cakrawala (“we,” “us,” or “our”), a company legally registered in Indonesia. Our registered address: Jl. Manunggal Pratama No. 8, Cipinang Melayu, Makasar, East Jakarta Administrative City, DKI Jakarta 13620, Indonesia.

We act as the Data Controller for all personal data processed through the menurutlo application and website (menurutlo.com). For privacy matters, contact our Data Protection Officer at privacy@menurutlo.com.

2. Legal Basis & Consent

By registering and using menurutlo, you explicitly consent to the collection and processing of your personal data as described in this policy.

You may withdraw your consent at any time by deleting your account (Settings → Account → Delete Account) or by contacting privacy@menurutlo.com. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

For users under 18, consent is provided by a parent or guardian. Users aged 13–15 require verifiable parental consent before account activation.

3. Data We Collect

Account Information

• Full name, username, email address, phone number
• Date of birth (required for age verification — not displayed publicly)
• Profile photo, bio, and city
• Gender (optional)

Content You Create

• Posts, stories, videos, photos, and loops you upload
• Testimonials you send or receive
• Ask questions, votes, and poll responses
• Comments and direct messages (DMs)
• Mood selections and check-in data
• Voice recordings (processed for transcription and deleted within 24 hours)

Usage & Technical Data

• Device type, OS version, app version
• IP address and approximate location (city level)
• In-app behavior and feature usage (processed by Mixpanel)
• Crash reports and diagnostic data (processed by Sentry)

Verification Data

• Identity verification status (verified/not verified) — identity documents are not retained after verification is complete
• Year of birth derived from the verification process

4. How We Use Your Data

We do not use your data for purposes incompatible with those listed above without obtaining fresh consent.

5. Automated Processing & AI

menurutlo uses automated systems including:

• Feed ranking algorithm: Determines content shown in your For You feed based on engagement signals, interests, and recency.
• AI content moderation: Screens user-generated content for policy violations before publication.
• AI companion bots (Luna, Ray, Maudy, Lody): Clearly identified as AI characters, not humans. They cannot initiate contact with real users or access your private data beyond what you share in conversation.

You have the right to request human review of any automated decision that significantly affects you by contacting privacy@menurutlo.com.

6. Anonymous Testimonials

When you send an Anonymous Testimonial, your sender identity is stored in our database in encrypted form. It is never exposed to the recipient through any API, interface, or data export. It may only be accessed by our authorized team in response to a valid legal order or to investigate serious safety violations (including harm to minors or threats to life). We will not voluntarily disclose your identity without legal compulsion.

7. Data Sharing

We do not sell your personal data to any third party.

Service Providers (Data Processors)

We use the following third-party processors, each bound by data processing agreements:

Research Partners

Verified adult users who opt in to paid research may have their responses shared with brand partners. Only aggregated and de-identified data is shared — individual identities are never disclosed to research partners. Each research participation requires separate explicit consent.

Law Enforcement & Legal Process

We will disclose data to government authorities or law enforcement only when required by a valid and lawful legal process issued under Indonesian law or applicable international legal assistance treaties. Where permitted by law, we will notify affected users prior to disclosure. Legal requests may be directed to legal@menurutlo.com.

8. Cross-Border Data Transfers

As listed in Section 7, some of our service providers are located outside Indonesia, including in the United States. We ensure that all cross-border transfers are conducted with adequate safeguards, including contractual protections consistent with UU PDP Article 56. By using menurutlo, you acknowledge that your data may be processed in jurisdictions outside Indonesia.

9. Protection of Minor Users

• Users under 13 are blocked from registration at both the app and server level.
• Users aged 13–15 may only access the platform with verifiable parental consent.
• Users aged 16–17 may use most features but are not eligible for anonymous posting, paid research, or the Nearby feature (except a separate age-appropriate pool with fuzzy location and a 2km radius limit).
• We do not use data from users under 18 for advertising targeting.
• Parents or guardians may request access to, correction of, or deletion of their child's data by contacting privacy@menurutlo.com with proof of guardianship.

10. Your Rights

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your account and associated data
• Portability: Request your content in a portable, machine-readable format
• Objection: Object to processing based on legitimate interest
• Withdrawal of Consent: Withdraw consent for non-essential processing at any time
• Human Review: Request human review of automated decisions that significantly affect you

To exercise any of these rights, contact privacy@menurutlo.com. We will respond to access and correction requests within 14 business days, and deletion requests within 30 calendar days.

11. Data Retention

12. Cookies & Tracking

Website (menurutlo.com): We use essential cookies required for functionality and analytics cookies to understand usage. You may opt out of analytics cookies via your browser settings or a cookie consent banner.

Mobile App: We use analytics SDKs (Mixpanel, Sentry) to understand app usage and diagnose issues. You may opt out of non-essential analytics in Settings → Privacy → Data & Analytics.

We do not use third-party advertising cookies or cross-site tracking.

13. Security

We implement technical and organizational measures to protect your data, including:

• Encryption of sensitive data at rest and in transit
• Row-level security policies on our database
• Access controls limiting employee access to personal data
• Regular security reviews

No system is completely secure. In the event of a data breach that poses a material risk to your rights, we will notify affected users and the relevant authority in accordance with UU PDP requirements.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you via in-app notification and update the “Last updated” date at the top of this page. Continued use of menurutlo after notification constitutes acceptance of the updated policy.