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Personal Data Use Policy

I. PERSONAL DATA POLICY

This Personal Data Use Policy (“Policy“) is an agreement from the Personal Data Owner so that his/her personal data can be processed and utilized, among others, by PT LDC Indonesia and its subsidiaries.

‘Personal data’ means all information relating to an identified or identifiable person (that is, an individual) – for example, Your name, telephone number, email address and mailing address as contained in Law of the Republic of Indonesia Number 27 of 2022 regarding Personal Data Protection and as may be amended or supplemented from time to time (“Regulation”).

PT LDC Indonesia takes the protection of Your personal data seriously in accordance with the Regulation. Therefore, data protection and information security are an inseparable part of our company policy. In this Personal Data Policy, we set out information about how we process personal data if and when we collect personal data about You in connection with providing our products to You or when doing business with You.

We ask that You read this Policy carefully as it contains important information about the collection, use, processing and disclosure of personal data in our possession or under our control.

II. HOW TO USE THE PERSONAL DATA POLICY

We have written this Personal Data Policy in a straightforward and easy-to-understand manner. You are welcome to read it from beginning to end.

To get information about Your rights:

  • to limit the information You provide to us
  • to withdraw consent; choosing to stop marketing messages
  • data accuracy
  • access to personal data
  • correction of personal data
  • filing a complaint

III. GENERAL INFORMATION REGARDING HOW WE PROCESS PERSONAL DATA

a. General principles we apply when processing personal data

We collect personal data about You only for specific and legitimate purposes. We inform You of such purposes and we process such personal data only in a manner that is consistent with the specific and legitimate purposes for which we have informed You. We lawfully process personal data about You in accordance with applicable Regulation.

We collect personal data about You that is adequate and not excessive in relation to the purposes for which we process it. We take care to ensure that such personal data is accurate and relevant, and if necessary for the purposes for which we process it, we always update it to follow the relevant Regulation.

We keep personal data about You only for as long as it is necessary for legal and business purposes. During the retention of such personal data, we put in place reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, deletion, or similar risks.

b. Lawful processing basics

In accordance with the Regulation, You should provide consent before we collect, use, disclose and store (collectively, ‘Process’) personal data about You, unless there is an exception to the consent requirement.

IV. COLLECTION OF PERSONAL DATA

a. How we collect personal data about or relating to customers

The personal data we collect refers to data or information about You from which You can be identified either (a) from data only; or (b) from the data combined with other information that we may collect. both directly and indirectly.

b. The type of personal data we collect

We only collect personal data for purposes directly related to our business activities and for those purposes. We set out more specific information below, but in general:

  • when You initiate contact with us, we collect contact information from You that enables us to respond to You and that generally enables us to communicate with You, and send messages to You, for the purpose or purposes for which You contacted us – for example, name, passport number or other identification number, date of birth, gender, nationality, email address, telephone number, postal address, home address and IP address – if at any time we ask, please contact us at the ‘contact us’ listed below this.
  • we collect information about our relationship with You, such as the types of products we provide that You may need and information that helps us tailor our services to You.
  • we collect transaction information about how You interact with us, including questions, account information, transaction information when You purchase our products and transaction information may include payment method details for products purchased from us.

c. The type of personal data we collect

If You are a party with whom we do business, including if You work for a company that does business with us, us or our service providers, we may collect the following types of personal data about or relating to You:

  • contact information that enables communication with You – such as name information, username, work email address, work telephone number and mobile phone number;
  • about our business relationship with You and that helps us do business with You and/or with Your company, such as the types of products and/or services we provide that may be of interest to You and/or Your company and information that helps us customize services to You and/or Your company; and
  • transaction information about how You interact with us, including questions, account information, transaction information when You and/or Your company purchase our products and/or use our services and information about how you and/or Your company use our products and/or services.

d. How we use personal data

We use personal data regarding:

to fulfill Your and/or Your company’s requests for products and/or services and for related activities, such as product and/or service delivery, customer service, account/relationship management, support and training, and to provide other services related to You and/or Your company’s business relationship with us.

  • to send You marketing communications, including offers that may be targeted based on Your interests, business characteristics and location and/or Your company.
  • to administer surveys and to administer promotional events and to determine whether You and/or Your company are eligible for certain services or offers.
  • to provide You and/or Your company with additional information that we think may be of interest to You and/or Your company, such as news about us, announcements we make, and technical information such as technical service newsletter.
  • to manage the day-to-day business needs and interactions with You and/or Your company, including delivering products and/or services to You and/or Your company, processing payments, managing financial accounting, conducting product research and development, administering the website, analyzing Your and/or Your company’s use of the services, preventing fraud and maintaining the security of systems and processes, reporting and legal compliance and managing our business continuity.

e. When we disclose personal data about or related to You

We do not sell Your personal data. However, we reveal it as follows:

  • to our subsidiaries and related companies, business partners, joint venture partners, agents, contractors, third party service providers, auditors, consultants, lawyers, advisors;
  • third party to whom You authorize the disclosure of Your personal data;
  • when we engage a third-party service provider to help us carry out activities where we collect and use personal data, such as the person who provides services to us (such as delivery of physical products, audit services, and other internal management purposes) – in this case, the third-party service provider is under a contractual agreement with us that requires the service provider to ensure that Your personal data is protected and not used by service provider for any purpose other than providing specific contractual services;
  • where we are required or permitted by law to disclose it.

V. ACCURACY

In order to ensure that Your personal data is current, complete and accurate, please inform us of any changes to Your personal data by notifying us in writing or via our e-mail.

VI. YOUR RIGHT

a. Limiting the information You provide to us

If we ask for personal data that You do not want to provide, please let us know and we shall try to proceed without that data.

b. Withdraw consent and opt out of receiving marketing messages

Where we have obtained your consent to process personal data, You can withdraw Your consent at any time. You can do this by notifying us in writing (including e-mail) as set out below.

c. Access to personal data

You can ask us to provide a copy of any personal data about You or referring to You that we have or under our control. We shall also provide You with information if we have, or may have, used or disclosed such data in the previous 12 months.

Please ask us in writing (including email) as stated below. We may request information from You that allows us to verify Your identity before fulfilling Your request. After verifying Your identity, we shall respond to your request as soon as possible. If we cannot respond to Your request within 30 days, we shall notify You within that time, when we can respond to Your request.

We reserve the right to charge a fee for access to Your personal data, which shall be limited to the additional costs we incur to fulfill Your request. We shall notify You of the amount (or, if it cannot be determined, an estimated amount) of fees before fulfilling Your request.

d. Correction of personal data

You can ask us to correct any errors or omissions of personal data about You or that refer to You that we have or under our control.

We may request information from You that allows us to verify Your identity before fulfilling Your request. After verifying Your identity, we shall respond to Your request as soon as possible. If we are unable to respond to Your request within 30 days, we shall notify You within that timeframe, when we shall be able to respond to Your request. We may also transfer the corrected personal data to other organizations to which we disclose Your personal data.

VII. SECURITY OF YOUR PERSONAL DATA

To protect Your personal data, we have appropriate security measures in place to prevent Your personal data from being accidentally lost, used, or accessed in an unauthorized, altered, or disclosed manner. We limit access to Your personal data to only employees, agents, contractors and other third parties who have a ‘need-to-know’ business. They shall process Your personal data only on our instructions, including to protect personal data from unwanted things.

We have procedures in place to deal with suspected personal data breaches and shall notify You and the applicable supervisory authorities of any actual or suspected personal data breaches where we are required by contract or law to do so.

You should be aware, however, that no method of transmission over the Internet or electronic method of storage is completely secure, and we cannot and do not guarantee that our systems or applications are immune to security breaches. We make no warranties, guarantees, or representations that the use of our systems or applications is safe and free from viruses, worms, trojan horses, and other vulnerabilities. For this reason, You hereby agree and agree to release Us from all demands, lawsuits, and/or fines from any party arising in connection with the collection, use or disclosure of Your personal data carried out by us.

VIII. RETENTION OF PERSONAL DATA

We retain Your personal data only for as long as we need the personal data to fulfill the purposes for which we collected it, and to fulfill our business and/or legal purposes, including audit, accounting or reporting requirements. In some circumstances, we may anonymize Your personal data so that it can no longer be associated with You, so we reserve the right to retain and use that data without restriction.

IX. TRANSFER OF PERSONAL DATA OVERSEAS

We may from time to time, depending on the circumstances in which You provide us with personal data, have a business need to transfer it (or a copy of it) outside the country in which You provided it to us and to one of our subsidiaries or related companies in another country. For example, if You provide it to us outside Singapore, we may need to transfer it to our regional headquarters in Singapore.

We have entered into a contract to ensure that personal data about or relating to You is treated by the receiving party with the same level of care as required by this Privacy Policy.

X. FILING A COMPLAINT

If You have a complaint regarding the way we process personal data about You or that refers to You – that is, if You feel we have not complied with our Privacy Policy and/or applicable data protection/privacy laws, please inform us. You can do this in writing (including email) as stated below. Please include the following details:

  • sufficient contact details to enable us to identify You;
  • clear and concise details about the circumstances of the complaint – for example, what happened, when You found out about it, and who was involved;
  • outline the impact of the event on You; and
  • details about what You expect to happen to resolve your complaint.

We shall confirm receipt of Your complaint as soon as possible. Then we shall investigate it. We may need to obtain further information from You, speak to relevant staff members, review relevant documents and/or obtain legal or technical advice to carry out our investigation. After completing the investigation, we shall reply to Your letter/email to inform You of the results of the investigation.

XI. HOW TO CONTACT US

You can contact us for further information regarding the Privacy Policy, to provide comments, or to submit a complaint by contacting our data protection officer as follows:

By letter: Wisma 46-Kota BNI 15th Floor, Suite 15.01, Jl. Jenderal Sudirman Kav. 1 Karet Tengsin-Tanah Abang, Jakarta Pusat, DKI Jakarta 10220

By email: [email protected]

By phone: +6221-570-6300

XII. AMENDMENT OF POLICY

We may amend and update this Privacy Policy from time to time, especially to comply with applicable Regulation. We shall notify You of such amendment by posting the amendment on our website. The amended Privacy Policy shall become effective since it is uploaded on our website.

XIII. WAIVER

All parties agree to set aside/ignore their respective rights and obligations based on applicable law in the event of termination of this Policy, to the extent that such law is required.

XIV. GOVERNING LAW

This Policy is governed by Indonesian law. For the avoidance of doubt, all applicable data protection laws shall apply to the processing of Your personal data.