A.   Introduction

This Privacy Policy forms an integral and inseparable part of the Terms and Conditions for the use of the website and/or the MyPertaLife application, owned and operated by PT Perta Life Insurance (“Perta Life”).

We respect and uphold the importance of Personal Data Protection as mandated by Law No. 27 of 2022 regarding Personal Data Protection (“UU PDP”) and its implementing regulations, as well as Financial Services Authority (OJK) Regulation No. 22 of 2023 regarding Consumer and Public Protection in the Financial Services Sector. Accordingly, We are committed to process Personal Data responsibly and in compliance with applicable data protection principles.

Under this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable individual, whether independently or in combination with other information, directly or indirectly, through electronic and/or non-electronic systems. Such data includes, but is not limited to: name, identification number, photograph, phone number, email address, financial data (including bank account details, credit card information, premium amounts, insurance benefit values, and transaction history), and other data that can reasonably be linked to your identity.

This Privacy Policy outlines how Perta Life performs Personal Data Processing, which encompasses: acquisition, collection, recording, processing, analysis, storage, rectification, updating, display, announcement, transfer, dissemination, disclosure, deletion, and/or destruction of your Personal Data. This applies to data processed through electronic systems, internal information systems, websites, applications, promotional programs, insurance services, and collaborations with third parties having a legal relationship with Us (“Third Parties”).

This Privacy Policy applies to:

• service users, prospective customers, or policyholders
• individuals or entities having a legal relationship with Us as business partners, contractors, agents, service providers, or other parties involved in our services or Corporate Social Responsibility (CSR) activities.

We encourage you to read and understand this Privacy Policy thoroughly to understand how We manage and protect your Personal Data.

 

B. Your Representations and Warranties Regarding the Provision of Personal Data

By providing Personal Data to PT Perta Life Insurance (“Us”/“We”), you represent and warrant that:

• You have read, understood, and agreed to the entire contents of this Privacy Policy;
• The Personal Data provided is true, complete, accurate, and valid for processing by Us;
• You acknowledge that any Processing of Personal Data performed by Us as stipulated in this Privacy Policy is conducted based on your consent and is subject to the applicable laws and regulations.

In the event that you provide Personal Data belonging to another party (including but not limited to a spouse, child, family member, or any party you represent), you hereby represent and warrant that you:

• Have obtained valid, explicit, and documented consent from the respective Personal Data subject to submit and authorize Us to perform Personal Data Processing as outlined in this Privacy Policy;
• Understand that We are entitled to rely on such representations and warranties in performing Our obligations and responsibilities regarding Personal Data management;
• Assume full responsibility for any legal consequences arising if such Personal Data is provided without a lawful basis.

We reserve the right, at any time, to request evidence of valid consent from the relevant third party, and you shall provide such documentation within a reasonable timeframe as requested by Us.

 

C.    Types of Personal Data Collected and Methods of Collection

The types of Personal Data collected from you will be tailored to the intended purposes of processing. In general, the Personal Data collected includes:

• Identity Data: Name, photograph, place and date of birth, gender, mother’s maiden name, and other identity information contained in official documents such as the National Identification Number (Nomor Induk Kependudukan/NIK), passport number, and driver’s license number (Surat Izin Mengemudi/SIM).
• Contact Data: Email address, phone number, and social media accounts.
• Financial Data: Bank account information, premium amounts, insurance benefit values, payment methods used in transactions related to the Services, credit scoring data, salary or income data, and financial history.
• Device Data: Including data pertaining to the device you use to access the Services, such as the type or model of device, Internet Protocol (IP) address, geographical location (geolocation) data required for the provision of the Services, and cookies used to personalize your experience when accessing the Services (you may manage cookies through your browser settings; however, this may affect the quality and speed of the Services).
• Other Personal Data: Other data in accordance with applicable laws and regulations, including medical history.

Personal Data is collected either directly from you or indirectly through third parties. Collection may be conducted through the completion of forms, submission of documents (electronic or non-electronic), scanning of QR codes, data uploads via websites, applications, or other systems, completion of online surveys, or through other media related to the Services. Furthermore, Personal Data may be collected when you register for or access the Services (including when you contact Us), participate in events organized by Us or Third Parties (whether online or offline), take part in promotional programs, participate in fundraising or donation activities, or through other services, products, or features related to the purposes of Personal Data processing.

Personal Data may also be obtained from third parties, for example in connection with Customer Due Diligence (CDD) processes, or from publicly available sources and authorized government institutions.

 

D. Processing of Your Personal Data

The processing of your Personal Data by PT Perta Life Insurance is carried out for various purposes, including the following:

1. Service Provision and Administration:
   a. Providing the Services and related information, including any updates or changes from time to time.
   b. Issuing your insurance policy in both digital and printed formats.
   c. Complying with applicable laws and regulations, including the implementation of Customer Due Diligence (CDD) principles, as well as Anti-Money Laundering (AML), Counter-Terrorism Financing (CFT), and Counter-Proliferation Financing of Weapons of Mass Destruction (CPF) programs related to the Services.
   d. Addressing and resolving your inquiries or requests regarding the Services.
   e. Modifying, enhancing, or developing the Services, including updates or adjustments to applications or systems related thereto.
   f. Fulfilling other necessary requirements related to the Services.
2. Operational Implementation and Enhancement:
   a. Conducting research and studies related to the provision of the Services, including generating data analysis and usage pattern insights for product development, trend identification, and assessing the effectiveness of promotional campaigns and business operations.
   b. Processing billing and payment collections for the Services.
   c. Performing accounting, auditing, taxation, reconciliation, and general internal administration related to the provision of the Services.
   d. Fulfilling contractual obligations, including where You are Our customer, for the processing Personal Data related to insurance benefits, claims, notices, health services, and coordinating with relevant third parties.
   e. Preventing, detecting, and investigating suspicious transactions, fraudulent acts, or other unlawful activities.
   f. Communicating with you through various channels to respond to inquiries or complaints.
   g. Managing your participation in contests, promotions, polls, and surveys.
   h. Executing internal technical activities such as software troubleshooting and data analysis.
   i. Managing employment-related processes, including recruitment, training, development, and promotion.
   j. Complying with law enforcement requests and protecting the rights of both the Company and the Data Subject.
   k. Fulfilling other operational requirements.
3. Marketing and Promotional Offers:
   We may offer the Services, other products, competitions, loyalty programs, prize draws, events, and other promotions tailored to your needs and profile. These offers may be delivered via various media, oral or written communication, including push notifications, social media, instant messaging (e.g., WhatsApp), SMS, phone calls, email, QR code scanning, brochures, or other relevant media in accordance with prevailing regulations.
4. Personal Data Processing in Corporate Transactions:
   We may process Personal Data in connection with corporate actions and other transactions, including but not limited to mergers, demergers, acquisitions, consolidations, or restructurings, which may involve the transfer of intellectual property rights.
5. Personal Data Processing based on Government Mandates:
   PT Perta Life Insurance may process Personal Data when requested or required by authorized government agencies for the aforementioned legal compliance or in accordance with applicable laws and regulations.

 

E. Legal Basis for the Processing of Your Personal Data by PT Perta Life Insurance

The legal basis for the processing of your Personal Data by PT Perta Life Insurance is as follows:

1. Your valid and explicit consent to this Privacy Policy.
2. The performance of a contractual obligations to provide Services to you or for other purposes in accordance with the provisions of this Privacy Policy.
3. Compliance with a legal obligation to which the Company is subject under applicable laws and regulations.
4. Processing based on the legitimate interests of PT Perta Life Insurance, with due consideration to the purpose, necessity, and the balance between the interests of the Company as the Personal Data Controller and your rights as the Data Subject.
5. Other legal bases as permitted under applicable laws and regulations.

 

F. Personal Data Processing by Third Parties

PT Perta Life Insurance may share or disclose your Personal Data to Third Parties for further processing in accordance with the legal bases set out in this Privacy Policy, for various activities and purposes.

In the event that you are registered as a user of services provided by a Third Party, you hereby consent that the Personal Data provided to PT Perta Life Insurance may be processed by such Third Party in accordance with the provisions of this Privacy Policy.

The list of Third Parties authorized to process your Personal Data may change from time to time, and you may access the most recent information regarding such list through PT Perta Life Insurance’s website, applications, or systems. If you are a policyholder, the list of Third Parties may be found in the forms or documents provided at the time of insurance closing or policy issuance. You are responsible for reviewing such list periodically.

 

G. Storage, Retention, and Security of Personal Data

1. You hereby consent to PT Perta Life Insurance transferring, storing, using, and processing your Personal Data on servers located in designated data centers. Such data centers may be managed by Third Parties in accordance with applicable laws and regulations.
2. Your Personal Data may be stored in PT Perta Life Insurance’s databases for a period of five (5) years or in accordance with applicable regulatory requirements, for the purposes of processing and service provision. Once your Personal Data is no longer required, necessary measures will be taken, such as deletion, destruction, or anonymization of your Personal Data.
3. Your Personal Data may be stored or controlled by Third Parties, including government authorities, for the purposes of Personal Data processing as referred to in this Privacy Policy. You acknowledge that the storage of Personal Data by government authorities or relevant institutions shall be subject to the retention policies applicable to such entities.
4. PT Perta Life Insurance endeavors to maintain appropriate physical, technical, and organizational security measures to protect your Personal Data against loss, misuse, or unauthorized access and disclosure.
5. Notwithstanding the implementation of best security practices, PT Perta Life Insurance cannot fully guarantee the security of your Personal Data. You understand that the use of electronic media involves inherent risks, and PT Perta Life Insurance shall not be held liable for any security breaches caused by factors beyond the Company’s reasonable control.
6. You may request further information regarding PT Perta Life Insurance’s efforts to safeguard your Personal Data through the contact channels provided in this Privacy Policy.
7. You hereby indemnify and hold harmless PT Perta Life Insurance from any liability or loss arising from the unauthorized dissemination of your Personal Data caused by your own negligence or improper use of electronic media.

 

H. Cross-Border Personal Data Transfer

If you access or use the website, applications, and/or systems related to the Services in another country (outside the Republic of Indonesia) where such services are accessible (“Destination Country”), PT Perta Life Insurance may transfer your Personal Data from your country of origin (“Country of Origin”) to the Destination Country to facilitate your access to Our platforms. You hereby understand and consent to the transfer of your Personal Data outside of your Country of Origin and/or the Republic of Indonesia as described in this Privacy Policy.

Furthermore, PT Perta Life Insurance may transfer your Personal Data outside the jurisdiction of the Republic of Indonesia, and where required, We may provide you with further details regarding such transfers.

We will comply with all applicable laws and regulations and exercise our best efforts to ensure a level of protection equivalent to that provided under Indonesian law, including through the use of standard contractual clauses or other appropriate safeguards for cross-border Personal Data transfers, where relevant and required.

 

I. Your Rights as a Data Subject

As a Data Subject, you are entitled to the rights stipulated under applicable laws and regulations regarding Personal Data protection. PT Perta Life Insurance is committed to ensuring you can exercise your rights in relation to the Processing of Personal Data, subject to applicable laws and regulations (including any limitations and exceptions), as follows:

• The right to obtain clarity regarding identity, legal basis, purposes of the request and use of Personal Data, and the accountability of the party requesting Personal Data (as set out in this Privacy Policy);
• The right to access and/or obtain copies of your Personal Data held by Us;
• The right to complete, update, and/or rectify any errors and/or inaccuracies in your Personal Data;
• The right to terminate processing, including the request for deletion and/or destruction of Personal Data, even if the purposes of processing and/or retention periods have not yet been fulfilled;
• The right to delete Personal Data where the purposes of processing and/or the retention period of Personal Data have not yet been fulfilled, including by requesting the destruction of Personal Data;
• The right to obtain and/or use Personal Data in a form that is consistent with structures and/or formats commonly used or readable by electronic systems (the right to portability), as well as the right to use and transmit Personal Data to other Personal Data controllers, provided that the systems used can communicate with each other securely in accordance with Personal Data protection principles based on statutory provisions (the right to interoperability);
• The right to withdraw consent for the Processing of Personal Data if the basis for such Processing is valid and explicit consent;
• The right to refuse to receive information and offers for marketing purposes as stated in the marketing messages you receive from Us;
• The right to object to decision-making based solely on automated processing, including profiling, which produces legal effects or significantly impacts you as a Data Subject;
• The right to delay or restrict the Processing of Personal Data proportionately in accordance with the purposes of Personal Data Processing if:
  – You contest the accuracy or correctness of the Personal Data processed by Us;
  – The Processing of Personal Data is carried out unlawfully, but you do not request the deletion of the Personal Data;
  – We no longer need the Personal Data, but you have a legal interest for legal proceedings;
  – You object to decision-making actions based solely on automated processing;
• The right to sue and receive compensation in the event of a violation of Personal Data Processing carried out by PT Perta Life Insurance that causes you loss, based on applicable laws and regulations.

To submit a request related to your rights, you may do so through the channels/contacts listed in Section J of this Privacy Policy. Please note that the exercise of such rights may result in the suspension or disruption of Service provision, account deletion, and/or termination of the contractual relationship between you and PT Perta Life Insurance.

We will conduct a verification process for your request to exercise your rights as a Data Subject. If your request is verified, We will inform you of the consequences of exercising those rights. Upon your approval, We will carry out your request within the time limits determined by applicable laws and regulations.

However, it must be understood that under certain conditions and based on applicable laws and regulations, PT Perta Life Insurance reserves the right to refuse your request, especially if it may impact the following:
– National defense and security interests;
– Law enforcement interests;
– Financial services sector supervisory interests;
– Statistical and scientific research interests;
– The necessity to implement statutory provisions;
– The interest of preventing criminal acts;
– The reasons for the request are irrelevant to the processing being carried out;
– Endangering the security or health of the Data Subject or other persons;
– Impacting the disclosure of Personal Data belonging to other persons.
– We may charge an administrative fee for each request related to the exercise of your rights in accordance with applicable statutory provisions.

 

J. Contact Us

If you have any questions or complaints regarding this Privacy Policy and the Processing of Personal Data carried out by Us, including if you intend to exercise your rights as a Data Subject, you may contact Us through the following channels:

– Email: hello@ptpertalife.co.id
– Telephone: 1500 282
– WhatsApp: +62 8952 1500 282
– Mailing Address: PT Perta Life Insurance, Pondok Indah Office Tower 3, 1st Floor, Jl. Sultan Iskandar Muda Kav. V-TA, Pondok Indah, South Jakarta 12310, Indonesia

 

K. Online Communications

1. If you send emails to Us, please do not include information that you wish to remain confidential. There is a possibility that your email communications may be accessed or viewed without authorization by other internet users while in transit. If you wish to provide information that you consider confidential, please use a method other than email.
2. We may send newsletters and electronic information regarding Our products or services, as well as other marketing communications. If you do not wish to receive marketing emails from Us, you may opt out by clicking the unsubscribe link provided at the bottom of each email. Please note that this unsubscribe feature applies only to marketing communications; We will still contact you via email for administrative purposes.
3. Spam, spyware, or viruses are strictly prohibited on Our website, applications, and/or systems. Please set and maintain your communication preferences (whether via email, live chat, WhatsApp Messenger, or telephone) so that We can deliver messages according to your choice. You must not transmit messages containing spam, spyware, or viruses through Our website, application, and/or systems. If you wish to report suspicious messages, please contact Us through the channels set out in Section J of this Privacy Policy.

 

L. Language

This Privacy Policy may be translated into languages other than Indonesian. In the event of any inconsistency or conflict between the Indonesian version of this Privacy Policy and any version in another language, the Indonesian version shall prevail.

 

M. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Indonesia.

 

N. Amendments or Updates to the Privacy Policy

We may amend, supplement, and/or replace this Privacy Policy from time to time (with notice to you) to ensure that this Privacy Policy remains aligned with Our procedures and practices in carrying out the Processing of Personal Data, including to comply with applicable laws and regulations.

You may review this Privacy Policy periodically on Our website and/or application under the Privacy Policy page.