The development of e-commerce transactions has increased the use and processing of consumers’ personal data in electronic-based commercial relationships. Data such as names, telephone numbers, addresses, and transaction information are necessary for the performance of transactions, but at the same time create risks of misuse by unauthorized parties. This study aims to analyze the construction of personal data protection as part of contractual obligations in e-commerce transactions and the construction of civil liability in the event of a violation of such obligations. This study employs a normative juridical method using a statutory approach and a conceptual approach. Legal materials are analyzed qualitatively by examining the relationship between the law of obligations and contracts under the Indonesian Civil Code, the Personal Data Protection Law, and regulations governing electronic transactions and electronic commerce. The results show that personal data protection obligations can be constructed as contractual obligations because data processing is carried out in the context of performing legal relationships between the parties. Such obligations are reinforced by the principles of good faith and propriety under Articles 1338 paragraph (3) and 1339 of the Indonesian Civil Code, as well as Article 20 paragraph (2) letter b of the Personal Data Protection Law. Violations of these obligations may give rise to civil liability based on breach of contract or unlawful acts, taking into account the position, obligations, violation, loss, and causal relationship attributable to each party involved in data processing.
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