This Privacy and Data Protection Policy sets forth the institutional standards under which PT AIA Berlian International (operating commercially as AIA BERLIAN INTERNATIONAL and AIA Corporates) collects, safeguards, processes, and transmits data collected through our corporate portal, commercial trade desks, digital RFQ submission systems, and Web3 settlement interfaces.
The primary Data Controller responsible for all processing activities is:
PT AIA Berlian International (Data Controller)
Menara Astra, Level 38, Jl. Jend. Sudirman Kav. 5-6, Jakarta Pusat 10220, Republic of Indonesia
Corporate Registration / NIB: Duly incorporated under the laws of the Republic of Indonesia.
Contact Email: [email protected] | Legal Hotline: +62 87881111786
This policy applies equally across all operating subsidiaries, regional physical trading hubs (Singapore, Dubai, Rotterdam), and chartering entities. Our operations strictly comply with the Indonesian Personal Data Protection Act (Undang-Undang No. 27 Tahun 2022 tentang Pelindungan Data Pribadi / UU PDP), as well as applicable international standards including the European Union General Data Protection Regulation (EU GDPR) for our European clean petroleum arbitrage corridor.
Given the institutional, wholesale nature of international petroleum trading, our data collection is structured around principal-to-principal counterparty verification, maritime logistics, and statutory trade compliance:
Commercial Inquiries & RFQs
Trader/officer name, corporate job title, institutional email address, corporate telephone/WhatsApp, company legal entity, commodity specification (EN590, Jet A-1, Crude), target volumes, discharge port, and banking mechanism preference.
KYB / AML Counterparty Records
Articles of incorporation, certificates of incumbency, ultimate beneficial ownership (UBO) declarations, certified identification documents of authorized signatories, and international sanctions check disclosures.
Maritime & Cargo Documentation
Vessel IMO details, NOR (Notice of Readiness) filings, port agent communications, certified laboratory assays (SGS, Saybolt, Intertek), and Bills of Lading consignee consignments.
Web3 & Cryptographic Signatures
Public Sui network wallet addresses, smart contract transaction hashes, and on-chain document proof digests. Notice: We never collect, manage, or store private keys or seed phrases.
| Data Category | Primary Source | Purpose | Legal Basis (UU PDP) |
| Commercial RFQ & B2B Contact | Trading Desk Forms, Direct Email | Parcelling, price quotations, contract formulation | Contractual Necessity (Pasal 20 ayat 2b) |
| Corporate KYB & Officer IDs | Onboarding Submissions, Due Diligence | Anti-Money Laundering, OFAC/UN Sanctions clearance | Legal & Statutory Obligation (Pasal 20 ayat 2c) |
| Banking & LC MT700 Records | Financial Institutions, Swift Transmissions | Trade finance settlement, escrow verification | Contractual Execution & Legitimate Interest |
| Technical & Telemetry Data | Automated Server Logs, Security Handshakes | DDoS mitigation, TLS cipher enforcement, audit trails | Legitimate Interest / Information Security |
Every data element processed by AIA BERLIAN INTERNATIONAL is tied directly to legitimate international trade workflows:
- Execution of Physical Petroleum Sales: Drafting and executing Sales and Purchase Agreements (SPA), Vessel Charterparties, Tank Storage Agreements (TSA), and Certificates of Origin.
- Mandatory Trade Sanctions Screening: Automated and manual screening against OFAC, EU Financial Sanctions, United Nations Security Council, and maritime blacklists prior to cargo lifting.
- Accredited Laboratory & Assay Logistics: Sharing consignee and vessel particulars with accredited third-party inspection firms (ASTM, ISO, DEF STAN certifications) to confirm cargo quality before title transfer.
- Trade Finance Administration: Transmitting commercial invoices, packing lists, and UCP 600-compliant Letter of Credit (DLC / SBLC) documentation to designated Tier-1 correspondent banks.
- Digital Provenance & Anti-Fraud Proofs: Verifying non-tampered bills of lading via Move smart contracts on the Sui blockchain.
Zero Data Monetization Guarantee: AIA BERLIAN INTERNATIONAL does not sell, lease, barter, or distribute corporate counterparty intelligence, contact lists, or transaction metrics to third-party advertisers or data brokers under any circumstances.
Petroleum trading operates across multinational maritime routes. To facilitate FOB/CIF transactions, personal and commercial counterparty data may be accessed by or transmitted to our regional physical hubs and accredited logistics partners located in:
- Republic of Indonesia (HQ): Executive management, trade finance legal clearance, and regulatory oversight.
- Republic of Singapore: Asian trading desk, bunker brokerage, and Jurong Island terminal logistics.
- United Arab Emirates (Dubai DMCC / Fujairah): Middle East refinery offtake positioning, STS lightering, and bunker blends.
- The Netherlands (Rotterdam / ARA): Northwest European import hub, bonded tank reservations, and ICE arbitrage clearing.
In adherence to UU PDP Pasal 56 regarding International Personal Data Transfers, all cross-border transmissions occur under verified safeguards, including standard bilateral data protection agreements, end-to-end encryption (TLS 1.3 / AES-256), and verification that recipient jurisdictions maintain equal or greater data security standards.
AIA Corporates incorporates decentralized Move modules on the Sui blockchain for supply chain cryptographic validation and settlement automation. Understanding privacy in Web3 environments is paramount:
Decoupled Architecture: Personal identifiers, KYC records, and corporate banking arrangements are strictly stored in private, encrypted off-chain enterprise databases. Only zero-knowledge cryptographic hashes (SHA-256) of verified cargo documents are broadcast to the public blockchain.
Please note the following technical principles:
- Public Blockchain Immutability: Transactions broadcast to the Sui blockchain (such as smart contract escrow states or tokenized commodity receipts) are permanent and publicly auditable. Do not include personal identity markers in on-chain transaction memos.
- Non-Custodial Architecture: Counterparties retain complete control of their digital asset custody. AIA BERLIAN INTERNATIONAL never holds, requests, or has access to your private cryptographic keys.
- Regulatory Compliance: Digital commodity operations comply with Indonesian OJK Digital Financial Asset Frameworks (PADK 3/2026) and international anti-financial crime guidelines.
All commercial dialogues, allocation availability notices, refinery discounts, and pricing formulas (Platts/Argus index differentials) shared with AIA BERLIAN INTERNATIONAL are treated with strict institutional confidentiality.
We honor customary International Chamber of Commerce (ICC) Non-Circumvention, Non-Disclosure (NCND) principles. Your corporate identity, buyer mandates, supplier refinery paths, and financial capabilities are safeguarded behind role-based security access, restricted solely to authorized trading officers directly executing your parcel.
We maintain comprehensive technical and operational safeguards designed to prevent unauthorized access, loss, or manipulation of trading intelligence:
256-Bit TLS & At-Rest Encryption
All web traffic, digital RFQs, and internal communications utilize enterprise TLS 1.3 encryption. Backups and database volumes are secured with AES-256 ciphering.
10-Year Statutory Retention
In compliance with the Indonesian Commercial Code (KUHD) and maritime tax obligations, physical trade contracts, financial receipts, and assay manifests are retained for a minimum of 10 years.
Role-Based Access Control (RBAC)
Internal employee access to counterparty KYC files and commercial banking instruments requires multi-factor cryptographic authentication and senior desk authorization.
Audit Logging & Breach Response
Real-time security telemetry monitors system integrity. In the unlikely event of a data security incident, notifications will be issued to affected parties and regulatory authorities within 72 hours.
Under the Indonesian Personal Data Protection Act (UU PDP No. 27/2022) and international privacy laws, authorized corporate representatives and individuals possess specific statutory rights regarding their personal data:
- Right to Information (Hak atas Informasi): Right to obtain clarity regarding the identity of the controller, legal basis, and purpose of processing.
- Right to Access (Hak Akses): Right to request an official copy of your personal data maintained within our trade management databases.
- Right to Rectification (Hak Pemutakhiran): Right to correct or update inaccurate, incomplete, or outdated personal information.
- Right to Erasure (Hak Penghapusan): Right to demand deletion of personal data when the processing purpose has been fulfilled, subject to mandatory maritime trade and tax retention laws.
- Right to Object & Restrict (Hak Pembatasan): Right to restrict processing in cases of disputed accuracy or unlawful processing.
- Right to Data Portability (Hak Transfer Data): Right to receive your personal data in a structured, commonly used electronic format.
To exercise any of these rights, please submit a formal written request to our Data Protection Officer at [email protected]. Identity verification will be required prior to releasing sensitive trade records.
The AIA Corporates portal utilizes strictly minimal cookies and browser local storage essential for secure and functional portal performance:
- Strictly Necessary Session Cookies: Maintain secure session integrity, CSRF tokens for RFQ inquiry transmission, and navigation preferences.
- Security & Load Balancing Cookies: Utilized by our edge delivery network to detect automated scraping and prevent distributed denial-of-service (DDoS) attacks.
- Language & Region Settings: Remember regional preference indicators (e.g. English / Indonesian localization).
We do not deploy invasive third-party cross-site behavioral tracking cookies, advertising ad-network pixels, or third-party behavioral profiling scripts.
For questions regarding this policy, corporate counterparty due diligence, statutory data rights requests, or regulatory filings, please contact our designated compliance team:
Data Protection Officer (DPO)
PT AIA Berlian International
Menara Astra, Level 38
Jl. Jend. Sudirman Kav. 5-6
Jakarta Pusat 10220, Indonesia
[email protected] Regulatory Escalation: If you believe your data has been processed in violation of Indonesian PDP Law, you also retain the right to submit a formal report to the Indonesian Personal Data Protection Authority (Lembaga Pelindungan Data Pribadi) in accordance with prevailing statutory mechanisms.
