Privacy Notice

Last updated: 9 October 2026

1. Who we are and what this notice covers

Claro is a phishing simulation and human risk management platform developed and operated by PT Alpha Code Technologies ("AlphaCode", "we", "us"), a company established in Indonesia. This notice explains how we process personal data when you visit getclaro.tech, when you use the Claro platform as an administrator or learner, and when you use Claro's reporting tools: the Outlook add-in, the Gmail extension and the public reporting portal.

We process personal data in line with Law of the Republic of Indonesia No. 27 of 2022 on Personal Data Protection (UU PDP). Where the EU General Data Protection Regulation (GDPR) applies to a client or an individual, we meet its requirements as well.

Claro is offered as a managed service and as an on-premise deployment. In an on-premise deployment the client runs Claro on its own infrastructure and decides where data is stored and which optional external services are switched on, so the hosting and provider details in sections 8 and 9 apply only to the extent the client enables them.

2. Our role: controller or processor

UU PDP distinguishes a personal data controller, which decides why and how personal data is processed, from a personal data processor, which processes it on the controller's behalf. Our role depends on whose data it is.

DataWhose dataOur role
Employee directory, simulation results, training and assessment records, reported emailsEmployees and other people a client organisation enrols in ClaroProcessor. The client organisation, usually your employer, is the controller: it decides who is enrolled, which simulations run and how long records are kept.
Accounts used to run Claro for a clientClient staff with an administrator, campaign manager or analyst roleProcessor for the client's workspace; controller for platform security and service communications
Website visits, contact and demo requests, Ransomware Exposure Check sign-upsVisitors to getclaro.tech and prospective clientsController

If a Claro client enrolled you, that organisation is your first point of contact for questions about why you are enrolled and how your results are used, and its own privacy notice governs that processing. We process your data only on its documented instructions and under our agreement with it.

3. Personal data we process

People enrolled by a client organisation

CategoryExamplesSource
Identity and contactFirst and last name, work email address, and a mobile number if the client runs voice, SMS or WhatsApp simulationsThe client, by CSV import, directory sync (LDAP or Active Directory), SCIM provisioning, single sign-on or manual entry
Work contextJob title, department, groups, manager, preferred language, role in ClaroThe client or its directory; you can edit some of these on your profile
Simulation activityWhether a simulated email, SMS, WhatsApp message or call was delivered, opened, clicked, submitted or reported, and when; for web events, the IP address, the browser user agent and the device type and browser derived from it; the keys pressed during a simulated callGenerated when you interact with a simulation
Training and assessmentAssigned modules, progress, quiz and exam answers and scores, completion dates, certificatesGenerated when you use the learner portal
Behaviour and engagementIndividual risk score, points, achievements, streaks, leaderboard position, behaviour observationsCalculated by Claro from the records above
Reported emailsEmails you report as suspicious, including headers, body, sender address and subject, and the result of any analysisYou, through the Outlook add-in, the Gmail extension, the reporting portal or the email analysis tool
Account and securityPassword hash (none for single sign-on users), sign-in activity, audit log entries of actions taken, with IP addresses stored encryptedGenerated when you sign in and use Claro

Other people in reported emails

When a reported email is not one of our simulations, it is a real email and can contain personal data about people who have no relationship with Claro, such as its sender and other recipients. We store it only so the client's security team can review the report, and it is deleted together with the client's workspace.

Website visitors and prospective clients

  • Contact and demo requests: name, company, work email, and optionally phone number, role and message. The form is delivered to our team by email and is not stored in the Claro platform database.
  • Ransomware Exposure Check: your work email address (stored encrypted), its organisation domain, the domain you looked up, your language and the results prepared for you, including the PDF briefing.
  • Analytics, only if you accept cookies: pages viewed, approximate location, device and browser information, and events such as a submitted form, collected by Google Analytics 4. We never send your name, email address, company or message to Google Analytics.
  • Technical data: every request to our servers carries an IP address and browser information, which our infrastructure uses to deliver and protect the service.

4. What we deliberately do not collect

  • Submitted credentials. When someone types a username or password into a simulated phishing page, Claro records only that a submission happened. The values typed are never read, stored or logged.
  • Call recordings. Simulated voice calls are never recorded. Claro keeps only the keys pressed to move through the call script and the outcome.
  • Import files. CSV files uploaded to import people are processed in memory and discarded, not saved.
  • Specific personal data. Claro does not ask for the specific categories of personal data listed in Article 4(2) UU PDP, such as health, biometric, genetic, criminal record or personal financial data. Such data can still appear in an email that someone chooses to report.

5. Purposes and legal bases

Article 20 UU PDP requires a legal basis for each purpose. Where we act as processor, the client organisation determines the legal basis, typically its legitimate interest in protecting its systems or a legal obligation such as those set by OJK. Where we act as controller, we rely on the bases below.

PurposeData usedLegal basis
Running simulations, training, assessments, risk analytics and compliance reporting for a clientPeople enrolled by a client (section 3)Carried out for the client as its processor, under our service agreement
Creating and protecting accounts, including sign-in and audit trailsIdentity, account and security dataPerformance of our contract with the client; our legitimate interest in keeping the platform secure
Answering a contact or demo request and following upContact request dataSteps you ask us to take before a contract; our legitimate interest in responding to business enquiries
Preparing your Ransomware Exposure Check briefing and sending the verification emailExposure Check dataFulfilling the request you made; our legitimate interest in following up with your organisation about the results
Website analyticsAnalytics dataYour consent, given through the cookie banner, which you can withdraw at any time
Operating the service, diagnosing errors and preventing abuseTechnical data, logs and error reportsOur legitimate interest in a secure and reliable service
Meeting legal obligations and responding to lawful requestsOnly the data the obligation requiresCompliance with a legal obligation

We do not sell personal data, and we do not use client data for advertising.

6. AI features

AI features are switched on per client, and the client chooses the provider: Anthropic, OpenAI, NVIDIA, or a model it hosts itself. When a feature is used, Claro sends the provider only what that feature needs.

  • Personalised simulations: the recipient's first and last name, job title, department, manager's name and language, with the scenario written by the client's administrator. Email addresses and phone numbers are never included.
  • Email threat analysis: the content of an email that someone submits or reports for analysis, with technical signals Claro derives from it.
  • Template generation and behaviour nudges: the administrator's instructions and the context needed to tailor the content, such as job title, department and language.

A client administrator reviews and approves every AI-personalised simulation email before it is sent, and AI-written text in Claro reports is labelled as such.

7. Risk scores and automated decisions

Claro calculates an individual risk score from simulation results, reporting behaviour and training activity, and it can automatically assign training when someone fails a simulation. This is profiling. Claro itself makes no decision with legal or similarly significant effect about anyone: scores are a tool for the client's security team.

Under Article 10 UU PDP you may object to a decision based solely on automated processing, including profiling, that has legal consequences or a significant impact on you. Raise this with the organisation that enrolled you, and we will support it.

8. Service providers and other recipients

We share personal data only with the providers below, with the client organisation that enrolled you, and with authorities when the law requires it. Optional providers receive data only when a client switches on the related feature.

ProviderPurposeData involvedLocationWhen used
Google Cloud PlatformHosting the application, database, cache and file storageAll platform dataJakarta, IndonesiaAlways, for the managed service
CoralogixApplication log aggregationApplication logs, which are designed to exclude email addresses and secretsJakarta, IndonesiaAlways, for the managed service
Email deliverySending simulation, training and account emailsRecipient email address and message contentThe client's own sending domain, or Claro's system email provider when the client has noneAlways
SentryError monitoringError reports, with email addresses, phone numbers and access tokens removed before sendingOutside IndonesiaWhen enabled for the deployment
Anthropic, OpenAI, NVIDIAAI features (section 6)As described in section 6Outside IndonesiaOnly if the client enables AI and selects that provider
TwilioSimulated voice calls and SMSRecipient phone number, message text or call scriptOutside IndonesiaOnly for voice or SMS simulations, through the client's own Twilio account
Meta (WhatsApp Business Platform)Simulated WhatsApp messagesRecipient phone number and message contentOutside IndonesiaOnly for WhatsApp simulations, through the client's own account
ElevenLabsGenerating the voice used in simulated callsCall script textOutside IndonesiaOnly if the client uses voice generation
Microsoft (Graph, Teams), SlackMail allowlisting and notificationsMailbox and tenant configuration, notification contentAs configured by the clientOnly if the client connects them
Google AnalyticsWebsite analyticsAnalytics data (section 3)Outside IndonesiaOnly on getclaro.tech, and only after you accept cookies
Threat intelligence sourcesRansomware Exposure Check resultsThe domain you look up, never your email addressOutside IndonesiaWhen you use the Exposure Check

When a client connects its own systems, such as a single sign-on provider, SCIM directory, SIEM or webhook endpoint, Claro exchanges data with those systems on the client's instructions. They belong to the client and are not our providers.

9. Where data is stored and cross-border transfers

For the managed service, the application, database, cache and file storage run on Google Cloud Platform in Jakarta (region asia-southeast2), and application logs are sent to Coralogix in Jakarta. In the default configuration, client personal data does not leave Indonesia.

Data leaves Indonesia only when a client uses an optional feature that relies on a provider outside Indonesia (section 8), or when you accept analytics cookies on our website. Article 56 UU PDP permits such a transfer where the receiving country offers protection equal to or higher than UU PDP, where adequate and binding safeguards are in place, or with the data subject's consent. The client decides whether these features are enabled for its workspace.

10. How long we keep data

We keep personal data only as long as its purpose requires, the client's settings allow or the law obliges.

DataRetention
Profiles of people enrolled by a clientUntil the client removes the person or its subscription ends. A client can erase a person's identity at any time; their results then remain only in anonymised form.
Simulation activityAs set by the client, between 30 days and 10 years. If the client sets no limit, until its subscription ends.
IP address and browser data captured when a simulation is opened or clickedRemoved from the intake queue within 24 hours. The encrypted copy stored with the simulation result follows the row above.
Audit logsAs set by the client, at least 5 years to meet OJK POJK 11/2022 and at most 10 years. If no limit is set, until the subscription ends.
Training, assessment and certificate recordsFor the life of the client's subscription, as the client's compliance evidence
Reported emailsFor the life of the client's subscription
Generated compliance reports5 years, then deleted automatically
Ransomware Exposure Check sign-ups24 months, then deleted automatically
Contact and demo requestsIn our business email for as long as needed to handle the enquiry and any business relationship that follows
Database backupsUp to 7 days, on a rolling basis

When a client leaves

When a client ends its subscription, its workspace is suspended and scheduled for deletion after a grace period of 30 days by default, during which the client receives an export of its audit log. When the grace period ends, every database record and stored file belonging to the client is permanently deleted from our live systems, and its encryption key is destroyed last. Database backups taken before that point are not changed by this: until they expire within the backup period above, they still hold the client's data, including its encryption key and fields that are never encrypted, such as names, job titles and the content of reported emails. Our restore procedure requires every completed deletion to be applied again before a restored system is used, so a backup cannot bring a deleted workspace back. We keep a record that the deletion took place, which contains no personal data.

11. How we protect data

  • Email addresses, phone numbers, IP addresses and the credentials of connected services are encrypted at the application level with AES-256-GCM, using a separate encryption key for each client.
  • Searches on encrypted fields use keyed one-way hashes, so values do not need to be decrypted to be found.
  • Every record belongs to exactly one client workspace, and every query is filtered by that workspace.
  • Access within a workspace is limited by role (administrator, campaign manager, analyst, learner), and clients can require single sign-on through SAML 2.0.
  • Administrative actions are recorded in an audit log that the client can review and export.
  • Connections to Claro are encrypted in transit with TLS.
  • Logs and error reports are designed to exclude email addresses, phone numbers and access tokens.

Names and job titles are not encrypted at field level, so administrators can search for people; they are protected by the access controls above. No system is perfectly secure: if you believe you have found a security issue, contact us at the address in section 17.

12. Your rights

Under UU PDP you have the right to:

  • be informed of the controller's identity, the purpose and legal basis of processing and how your data is used;
  • access your personal data and obtain a copy of it;
  • correct data that is inaccurate or incomplete;
  • end the processing of your data and have it deleted or destroyed;
  • withdraw consent you have given;
  • object to decisions based solely on automated processing, including profiling (section 7);
  • have processing delayed or restricted in proportion to its purpose;
  • obtain your data in a commonly used, machine-readable format and have it sent to another controller; and
  • claim compensation for a violation in the processing of your data.

How to make a request

If an organisation enrolled you in Claro, send your request to that organisation, because it is the controller. Its administrators can export everything Claro holds about a person in a machine-readable file, correct profile data and erase a person's identity directly in Claro. If you contact us instead, we will pass your request to the organisation and help it respond.

For data we control (section 2), email privacy@alphacode.tech. We may ask you to confirm your identity first. UU PDP sets response deadlines, for example 3 x 24 hours to give access to or correct personal data. We respond within the deadline that applies to your request, and if we cannot fulfil it we tell you why.

Some requests have limits. A client may need to keep audit logs for 5 years under OJK regulations, and erasure in Claro removes a person's identity while keeping anonymised results as the client's compliance evidence.

13. Cookies and similar technologies

On getclaro.tech, Google Analytics loads only after you choose Accept on the cookie banner. If you decline or make no choice, the analytics script does not load and nothing is sent to Google. The Claro platform itself, including the admin console and the learner portal, uses no analytics cookies.

NamePurposeTypeDuration
access_tokenKeeps you signed in to ClaroStrictly necessary, HTTP-only15 minutes
refresh_tokenRenews your session without signing in againStrictly necessary, HTTP-only7 days
NEXT_LOCALE, claro_locale_syncedRemember your languageFunctional1 year
claro-cookie-consent (browser storage)Remembers your cookie choiceStrictly necessaryUntil you clear your browser storage
_ga, _ga_*Google Analytics measurementAnalytics, only with your consentUp to 2 years, set by Google

To change your choice, clear this site's cookies and storage in your browser and the banner will appear again on your next visit. Claro also keeps some interface preferences, such as a collapsed sidebar, in your browser's local storage on your device.

14. Personal data breaches

If a personal data breach occurs, we contain it and assess its impact. Where we are the controller, we notify the affected individuals and the authority in writing within 3 x 24 hours as Article 46 UU PDP requires, stating the data involved, when and how the breach occurred, and how it is being handled. Where we process data for a client, we notify the client without undue delay and give it the information it needs to meet its own notification obligations.

15. Children

Claro is designed for workplaces and is not directed at children, and we do not knowingly collect children's personal data through our website. If a client enrols anyone under 18, for example a student, the client is responsible for obtaining the parent or guardian consent required by Article 25 UU PDP.

16. Changes to this notice

We update this notice when our processing changes and revise the date at the top. When a change materially affects how we process data for clients, we also inform client administrators.

17. Contact us

Send privacy questions, requests and complaints to:

Privacy contactPT Alpha Code Technologiesprivacy@alphacode.tech

If you are not satisfied with our response, you may complain to the personal data protection authority established under UU PDP.

Privacy Notice: How Claro Processes Personal Data | Claro