1. Scope of this policy
This policy applies to the website www.sahaibat.com (including the Experience Zone), and to the SahAIbat products and services: SahAIbat Kader, SahAIbat Bidan, SahAIbat DOK, DOK Companion, Kasih, Code and Konsensus.id, together with their apps, browser extensions and support channels (the “Services”).
A product may have additional terms or an agreement with your organisation (for example a data processing agreement with a clinic). Where those are more protective, they apply in addition to this policy.
2. Who we are and our role
SahAIbat is a brand owned by 11679210 Canada Inc (Viantra Health). In Indonesia it operates as SahAIbat Health, and globally as Orivera (together “SahAIbat”, “we”). In Indonesia we hold NIB 1202260248509 and are registered as an Electronic System Operator (PSE) with the Ministry of Communication and Digital Affairs (Komdigi). Our address is Jl. Boulevard Raya No. 1, Kelapa Gading Timur, Kec. Kelapa Gading, Jakarta, DKI Jakarta 14240, Indonesia.
Under the UU PDP our role depends on whose data it is:
| Data | Our role | What it means |
|---|---|---|
| Patient and clinical records kept by a clinic, practice, midwife, Posyandu or hospital | Data Processor (Prosesor Data Pribadi) | The health facility is the Controller. We process the records only on its documented instructions and for no other purpose. |
| Accounts of doctors, midwives, kaders and clinic staff; billing; support; website visitors; Kasih users who sign up themselves | Data Controller (Pengendali Data Pribadi) | We decide why and how the data is processed, and we are accountable for it under this policy. |
If you are a patient and want to use your rights over your medical record, please contact your health facility first. We will help them respond, and you may also contact our Privacy Officer.
3. Privacy Officer (Data Protection Officer)
We have appointed a Privacy Officer, as required by Article 53 of the UU PDP, who oversees compliance with this policy and is your point of contact for any privacy question, request or complaint.
- Privacy Officer: Shindy Farah · shindyfarrah@sahaibat.com
- Privacy team: privacy@sahaibat.com
- Post: Privacy Officer, SahAIbat Health, Jl. Boulevard Raya No. 1, Kelapa Gading Timur, Jakarta 14240, Indonesia
4. Personal data we process
We collect only what each Service needs (data minimisation). Depending on the Service:
| Category | Examples | Source |
|---|---|---|
| Identity and contact | Name, NIK, date of birth, sex, address, phone, email, BPJS number | The patient or family, the health facility, or you |
| Health data (specific personal data) | Consultations, diagnoses, vital signs, prescriptions, lab and radiology results, pregnancy, birth, postnatal, family planning and immunisation records, child growth | Health workers using the Services |
| Children’s data (specific personal data) | Growth measurements, immunisation, development checks | Kaders, midwives and doctors, with the parent or guardian |
| Consultation recordings | Audio of a consultation, when the doctor chooses to record, to create a SOAP draft | The doctor, with the patient’s knowledge |
| Professional and account data | Name, STR/SIP, facility, role, login details, settings | You or your organisation |
| Billing data | Plan, invoices, payment status (card details are handled by the payment provider, not by us) | You |
| Technical and security data | IP address, device and browser type, access logs, a salted hash of the IP for rate limits | Your device |
| Communications | Messages to support, sales or partnerships, by email, WhatsApp or forms | You |
5. Why we process it, and the legal basis
We process personal data only for specified, explicit and legitimate purposes, each with a legal basis under Article 20 of the UU PDP:
| Purpose | Legal basis |
|---|---|
| Providing the Services: records, documentation, prescriptions, referrals, reports | Performance of a contract with the health facility or user; the facility’s legal duty to keep medical records |
| Sending data to SATUSEHAT and BPJS Kesehatan | Legal obligation of the health facility (Permenkes 24/2022; JKN rules) |
| SahAIbat Intelligence: drafting notes, guideline and drug-safety checks, reading reports | Performance of a contract, on the facility’s instructions; consent for recordings |
| Account management, billing, support | Performance of a contract |
| Security, fraud and abuse prevention, service reliability | Legitimate interest, balanced against your rights |
| Product news and offers to professional users | Consent, which you can withdraw at any time |
| Emergencies where someone’s life is at risk | Vital interests |
We do not use personal data for a new purpose that is incompatible with the original one without telling you and, where required, asking for consent.
6. Health data and children’s data
Health data and children’s data are specific personal data under Article 4 of the UU PDP. We apply stronger safeguards to them: encryption, strict role-based access, access logging, and a data protection impact assessment before any new processing that carries high risk.
Children’s data is processed with the consent or knowledge of a parent or legal guardian, as required by Article 25 of the UU PDP, and only for the child’s care.
7. Safe use of SahAIbat Intelligence
SahAIbat Intelligence (including DOK Intelligence) supports health workers; it never replaces them. These guardrails apply to every product:
| Guardrail | What it means |
|---|---|
| A person decides | Every note, code, plan or message is a draft until a qualified health worker reviews, edits and signs it. Diagnosis, treatment and referral are always decided by the health worker. |
| No automated decisions | Intelligence makes no decision with legal or similarly significant effect on a patient, and never contacts a patient on its own. Messages are sent only after a health worker approves them. |
| Calculated, not guessed | Clinical calculations and risk thresholds, such as WHO growth z-scores, pregnancy risk flags and drug-safety checks, are computed by fixed, tested rules. |
| Grounded in what was said | A note is never made from an empty recording. Lines that were inferred rather than said are marked, and drafts are checked against the consultation. |
| Indonesian standards | Clinical support follows national guidelines and professional bodies (such as Kemenkes, PERKI, PERKENI, IDAI and POGI), with the source shown. |
| Safe by design | Intelligence suggests no medicine dose that the health worker did not state, refuses requests that are not clinical, and treats text inside a record only as information, never as instructions. |
| Only what is needed | Each task uses only the data it needs, and only for that task. |
| Monitored and improved | Quality and safety are reviewed continuously. Any safety concern reported by a health worker is investigated, and fixes are tested before release. |
You have the right to object to decisions based solely on automated processing (Article 10 UU PDP). Contact us and a person will review it.
8. Model training: our commitment
Identifying details are never used to train any model: names, NIK, dates of birth, addresses, phone numbers, email addresses, BPJS numbers, photos or any other detail that identifies a patient, family, health worker or facility. Nor are account, billing or usage data, or demographic data used for profiling.
To make DOK Intelligence more accurate for Indonesian clinical language, we may learn from how doctors correct its drafts. When we do, these rules apply:
- Only facilities that agree in writing take part (opt-in). It is never switched on by default, and a facility can withdraw at any time, with its data removed from future training.
- Only the clinical text is used: the draft and the doctor’s signed correction. Identifying details are removed before any example is used, including names spoken during a consultation.
- Training runs only on infrastructure we operate in Jakarta. The data does not leave Indonesia for training, and the resulting model is never sold or shared with third parties.
- A data protection impact assessment is completed before training begins, and the model is checked so that it cannot reproduce an individual record.
- Our technology partners are never permitted to use our customers’ data to train their own models.
- Kader, Bidan, Kasih, Code, the Experience Zone and all other Services: no customer data of any kind is used for training.
9. Where your data is stored
All personal data and health records are stored in Indonesia, in secure data centres in Jakarta. Your records are not stored outside Indonesia.
Storing data in Indonesia keeps it under Indonesian law and supervision, in line with the UU PDP and the rules on electronic medical records.
10. Working offline
Our products are built to work without a connection, because many health posts in Indonesia have no reliable signal. When a device is offline, the data entered is saved on that device in encrypted storage, available only to the signed-in user, and sent to our servers in Indonesia when the connection returns. After a successful sync, the device keeps only what the user needs to keep working.
Health facilities are responsible for keeping their devices secure (a screen lock, and telling us at once if a device is lost or stolen so that we can sign it out). We can revoke a device’s access remotely.
12. How we protect data
Our information security controls are aligned with ISO/IEC 27001 and ISO/IEC 27701, and include:
- Encryption of clinical data at rest (AES-256-GCM) and in transit (TLS).
- NIK stored as a one-way hash for matching, so it is not readable in search.
- Role-based access: each person sees only what their role at their facility allows.
- An access log of who viewed or changed a record, available to the facility.
- Separation of each facility’s data, backups, and tested recovery.
- Confidentiality agreements, privacy training and least-privilege access for our staff.
- Security testing, vulnerability management and a documented incident response plan.
13. If a data breach happens
If a personal data breach occurs, we act at once to contain it. As required by Article 46 of the UU PDP, we notify the affected people and the relevant authority in writing within 3 × 24 hours, explaining what data was involved, when and how it happened, and what we are doing about it. Where we act as Processor, we notify the health facility without delay so that it can meet its own obligations.
14. How long we keep data
| Data | Retention |
|---|---|
| Medical records | As the health facility instructs, and at least as long as Permenkes 24/2022 requires (25 years from the last visit for electronic medical records) |
| Consultation recordings | Used to create the draft and not kept as part of the record, unless the facility chooses otherwise |
| Account and billing data | While the account is active, then as long as tax and accounting law requires (generally 10 years for financial records) |
| Support and enquiry messages | Up to 2 years after the last contact |
| Security and access logs | Up to 12 months, longer for an open investigation |
| Experience Zone text | Not stored. Rate-limit counters use a salted hash of the IP and expire within 24 hours |
When data is no longer needed, it is deleted or irreversibly anonymised.
15. Your rights
Under Articles 5 to 13 of the UU PDP you have the right to:
- Be informed about who processes your data, why, and on what basis.
- Access your data and get a copy.
- Correct inaccurate or incomplete data.
- Ask us to stop processing, delete or destroy your data, where the law allows.
- Withdraw consent you have given, at any time.
- Object to decisions based solely on automated processing, including profiling.
- Delay or restrict processing.
- Receive your data in a commonly used, machine-readable format, and have it sent to another controller.
- Claim compensation for a breach of the law in processing your data.
To use a right, email privacy@sahaibat.com or our Privacy Officer. We will verify your identity and respond within the time the UU PDP sets, generally 3 × 24 hours. There is no charge. Some rights are limited by other laws: a medical record, for example, cannot be deleted while the law requires the facility to keep it.
16. This website and the Experience Zone
- The website uses no advertising or tracking cookies and no third-party analytics.
- Your browser stores your language choice locally. It never leaves your device.
- The Experience Zone is a public demonstration. Please do not enter real patient information. Text containing a NIK, phone number or email address is refused.
- Text you type in the Experience Zone is used only to produce the demonstration. It is not stored, not linked to you, and not used for training.
- To prevent abuse, the Experience Zone uses Cloudflare Turnstile, which checks that a visitor is human, and counts runs using a salted hash of the IP address.
17. Laws and standards we follow
- UU No. 27 Tahun 2022 on Personal Data Protection (UU PDP)
- UU No. 17 Tahun 2023 on Health, and Permenkes No. 24 Tahun 2022 on Medical Records
- UU ITE and PP No. 71 Tahun 2019 on Electronic Systems and Transactions
- ISO/IEC 29100 privacy principles, ISO/IEC 27701 privacy information management and ISO/IEC 27001 information security, as the framework for our controls
18. Changes to this policy
We review this policy at least once a year. If we make a material change, we will tell users of the Services in the product or by email before it takes effect, and ask for consent where the law requires. The date and version at the top show the latest update.
19. Questions and complaints
Please contact our Privacy Officer first; we take every concern seriously and will reply in writing. If you are not satisfied, you may complain to the personal data protection authority in Indonesia or the Ministry of Communication and Digital Affairs (Komdigi). This policy is governed by the laws of the Republic of Indonesia. If the English and Bahasa Indonesia versions differ, the Bahasa Indonesia version prevails.
