GENERAL POLICIES & PRIVACY POLICY
PART I: PRIVACY POLICY & GLOBAL DATA PROTECTION STATEMENT
This Privacy Policy details how Graciella Prive Consulting (the "Brand"), operated by Graciella Media Universal (the "Company," "we," "us," or "our"), handles information processed through our SaaS platform, client-side analytical engines, and digital software solutions (the "Services").
As a premier software provider serving high-net-worth professionals, family offices, and institutional teams, we maintain enterprise-grade privacy standards and complete data transparency while minimizing operational friction. We adhere to global data protection principles, including the EU/UK General Data Protection Regulation (GDPR), the Swiss Federal Act on Data Protection (FADP), the US California Consumer Privacy Act (CCPA/CPRA), the Singapore Personal Data Protection Act (PDPA), the Australian Privacy Act, and international data privacy frameworks.
1.1. Data Controller Standard
This Policy details the data practices of Graciella Prive Consulting in its capacity as Data Controller. All SaaS applications, calculation tools, and digital utilities provided under the Brand operate under these enterprise security standards.
1.2. Corporate Governance
Graciella Media Universal, an entity incorporated under the laws of the Republic of Indonesia operating under the brand Graciella Prive Consulting, manages account identity data.
1.3. Privacy-First Local-First Application Architecture & Executive Export Utilities
Our software is engineered on an uncompromising privacy-first, client-side execution model. We do not host, store, back up, process, mine, or transmit operational data, project models, or business records on cloud servers. All operational data created inside the SaaS platform remains strictly within Your local device environment (LocalStorage / IndexedDB).
- Individual Elite Clients: Full native access to client-side PDF exports, direct hardcopy physical printing, and 1-click local JSON backup/restore file exports managed entirely on the local device environment.
- Elite Corporate Clients: Custom data backup architectures, corporate vault integrations, and automated storage rules tailored specifically to enterprise requirements during onboarding.
1.4. Identity Data Minimization
Personal data collection is strictly restricted to verifying identity, managing login credentials, validating active entitlement, and processing billing transactions.
2. Information We Collect
We collect strictly the identity and authentication data necessary to deliver, secure, and validate platform access:
| Category of Data | Specific Data Types | Primary Processing Purpose | Storage & Retention Standard |
|---|---|---|---|
| A. Identity & Account Data | Email address, Elite Client ID, encrypted password hash, IP address, login timestamps | Contractual Necessity: Registration, identity verification, multi-factor login authentication, entitlement checks. | Processed via secure cloud authentication infrastructure. Retained while account remains active. |
| B. Financial & Billing | Subscription tier, billing address, transaction history, masked transaction IDs | Contractual Necessity: Secure transaction processing and automated global tax compliance (VAT/GST). | Handled directly by PCI-DSS Level 1 compliant gateways. Card details are never stored on our servers due to our non-recurring structure. |
| C. Usage & Audit Trail | Operational usage logs, login timestamps, API authentication calls | Legitimate Interest: Maintaining Master Audit Trails, optimizing system performance, enforcing seat security. | Managed via secure platform monitoring engines. |
| D. Technical & Security | Browser type, device fingerprints, essential session tokens | Legitimate Interest: Anti-fraud detection (3DS2), active session security, platform stability. | Essential security session tokens managed locally/secretly. |
| E. Client Operational Work, PDF Exports & Backups | NOT COLLECTED OR TRANSMITTED (Financial inputs, model calculations, exported PDFs, local backup files) | N/A: All calculations, PDF generation, printing, and backup operations execute client-side inside the browser. | Individual Elite Client: 100% stored in client local device environment. Elite Corporate Client: Tailored per enterprise contract demand. |
PAYMENT CREDENTIALS NOTE: Credit card numbers, debit card details, CVVs, and bank accounts are processed exclusively by PCI-DSS compliant payment gateways on a single, non-recurring transaction basis. Payment card details are never collected, viewed, held, or stored on Company servers.
3. Purpose Limitation & AI Privacy Safeguards
Data is processed strictly to fulfill contractual obligations and manage platform security:
- a. Platform Delivery & Operations: Provisioning accounts, processing transactions, executing authentication calls, and rendering high-touch executive support.
- b. System Optimization: Utilizing anonymized aggregate system usage metrics to improve execution speed and UI responsiveness.
- c. Essential Communications: Dispatching required administrative notices, security alerts, receipts, and 60-day renewal courtesy advisories.
- d. Enterprise AI Privacy Safeguards: Customer prompts, inputs, and operational workflows processed through integrated software AI API endpoints are governed by strict zero-data-retention controls and are never used to train public machine learning models.
4. Data Sharing & Infrastructure Partners
We do not sell, lease, or rent Personal Data. Identity data is shared strictly with essential infrastructure providers required to operate the platform:
- a. Authentication Infrastructure: Third-party identity management providers handling identity verification and credential hashing.
- b. Payment Gateways & Tax Compliance Engines: PCI-DSS certified payment processors handling non-recurring checkout transactions and automated global VAT/GST calculation engines.
- c. Fraud Prevention Services: Global Merchant Risk Services (e.g., Ethoca, Verifi) utilized strictly for 3DS2 verification and fraud deterrence.
- d. Corporate Ecosystem Transfers: Basic identity records may be shared with parent or affiliated entities within our corporate structure strictly for technology integration under global privacy standards.
5. Global Privacy Rights & Executive Controls
Regardless of geographic location, we provide comprehensive account identity controls:
5.1. EU/UK GDPR & Swiss Data Rights
- Right to Access & Rectification: Request a copy of Your basic identity records or update account details.
- Right to Erasure (Right to be Forgotten): Request deletion of Your authentication profile, subject to statutory tax and accounting retention requirements.
- Data Portability: Account identity logs can be exported upon written request.
5.2. US State Privacy Rights (CCPA/CPRA)
- No Sale or Sharing: We explicitly certify that we do not sell or share personal data to third parties for monetary or targeted advertising purposes.
- No Sensitive Data Collection: We do not collect biometric data, precise geolocation, or financial card numbers on our infrastructure.
5.3. Global Framework Alignment
Data practices conform to minimization and accuracy standards under the Singapore Personal Data Protection Act (PDPA), Australian Privacy Act, and international frameworks.
5.4. Submitting Requests
Contact our Privacy Desk at help@support.graciellaprivesoft.com.
6. Eligibility & Capacity Standards (Age 20)
6.1. Minimum Age: The SaaS Platform is strictly designed for individuals aged twenty (20) years or older.
6.2. Statutory Capacity: By subscribing, You certify You are at least 20 years old and possess full legal capacity under applicable standards.
7. Official Privacy Contact & Support Channels
- In-Dashboard Member Desk: Active Elite Clients receive encrypted priority ticket support directly within the SaaS dashboard environment.
- Privacy Requests & Formal Inquiries: help@support.graciellaprivesoft.com
- General Support & Billing Desk: help@support.graciellaprivesoft.com
PART II: REFUND POLICY & EXECUTIVE GUARANTEE PROTOCOL
1. Overview
The Company offers transparent refund guarantees tailored to the license tier (Individual Elite Client vs. Elite Corporate Client) and transaction channel (Online Checkout vs. Bespoke Enterprise Procurement). All claims are governed by Section 4 of the General Terms & Conditions.
2. Standard Online Fixed-Term Refund Tiers
Individual Elite Clients and Online Corporate Clients purchasing via automated online checkout are subject to a 14-day tiered guarantee window from the Effective Date:
- Days 1–3 (100% Full Refund): Written request submitted within three (3) calendar days of purchase.
- Days 4–14 (50% Partial Refund): Written request submitted between the fourth (4th) and fourteenth (14th) calendar days of purchase.
- Day 15 Onward (0% Non-Refundable): All online sales are 100% final, non-cancellable, and non-refundable.
3. Institutional & Enterprise Refund Tiers
3.1. Online Corporate Checkout: Corporate licenses purchased directly via standard online automated checkout receive the identical 14-day tiered guarantee (100% Days 1–3; 50% Days 4–14; 0% Day 15+).
3.2. Bespoke Enterprise & Wire Transfer Transactions: For Elite Corporate Clients purchasing via manual procurement, customized Order Forms, corporate invoices, or direct bank wire transfers, all sales are strictly 100% final and non-refundable (0% Refund) upon payment or execution. Enterprise onboarding involves immediate dedicated technical resource allocation, custom API key generation, tailored backup pipeline customization, and bespoke seat provisioning.
4. Mandatory Refund Verification Procedure
- Submit a formal written request via email to help@support.graciellaprivesoft.com or via the in-dashboard Member Desk within the applicable guarantee window.
- Provide written certification confirming that all downloaded software assets, local cached components, exported JSON backup files, and exported PDFs have been permanently removed from local devices.
- Acknowledge that platform credentials and authentication access will be deactivated immediately upon request submission.
PART III: NOTICES, FINANCIAL ENVIRONMENT & CORPORATE INFORMATION
1. Contracting Entity
The SaaS Platform and digital services are provided by Graciella Media Universal, an entity incorporated under the laws of the Republic of Indonesia, operating under the primary brand Graciella Prive Consulting.
2. Brand Protection & Tort Law Mandate
- a. Reputational Malice: Legal remedies and civil actions under applicable tort laws will be pursued against any party spreading malicious, false, or defamatory statements regarding the Company, Brand, SaaS Platform, or leadership.
- b. Tortious Interference: Judicial proceedings will be initiated against any third party intentionally interfering with the Company's commercial relationships or corporate operations.
- c. Unauthorized Brand Use: Unauthorized deployment of company names, logos, proprietary software code, or system architecture constitutes actionable intellectual property infringement and tortious conduct.
- d. Global Legal Jurisdiction: The Company reserves the right to initiate legal proceedings in any jurisdiction where commercial or reputational damage occurs to protect global brand equity.
3. Governing Language & Translation Responsibility
Formal policies are published in English and headquarters translation (https://idterms.graciellaprivesoft.com). Accessing the platform confirms you have been provided a conspicuous opportunity to review terms in either language (https://idterms.graciellaprivesoft.com). Choosing not to review translations shall not impede enforcement of any provision herein.
4. Financial Environment & Security Standards
Automated Tax Standard: Checkout workflows utilize integrated third-party engines to calculate and collect international VAT and GST based on buyer location.
Global Inclusive Pricing: Quoted pricing factors in required international consumption taxes under a transparent "No Hidden Fees" policy.
3DS2 Authentication & Anti-Fraud: Electronic transactions utilize 3D Secure 2 (3DS2) verification. Successful 3DS2 verification serves as irrefutable proof of cardholder authorization. Fraudulent chargebacks will be reported to Global Merchant Risk Services (Ethoca/Verifi).
5. Official Service Address & Contact
Graciella Media Universal
Gedung AD Premier Lt. 9, Jl. TB. Simatupang No. 5, Pasar Minggu
Jakarta 12550, Indonesia
- Official Terms Link: https://graciellaprivesoft.com/terms
- Official Executive Desk: help@support.graciellaprivesoft.com
First Published: July 29th, 2026