PRIVACY POLICY

The following Privacy Policy describes how PT Asuransi Tugu Pratama Indonesia Tbk – Tugu Insurance (hereinafter referred to as the “Company” or “We” or “Tugu Insurance“) obtains, collects, uses, displays, publishes, discloses, processes, opens access, stores, transmits, provides, shares, processes, manages, destroys, protects, and/or cooperates with third party information technology service providers (collectively, “Use“) of your personal data which includes, among others, your full name, address, identity card number, telephone number, email address, date of birth and/or age, location of your existence (with the activation of the geolocation function on the mobile device) and other information in accordance with the provisions of laws and regulations (“Personal Data“) that you provide when you use the Company’s website/application “Our Website”, as well as data related to transactions that you make using the Website (“Transaction Data“). It is worth noting that Personal Data here does not include Personal Data that has been made publicly available.

This Privacy Policy forms part of the Terms & Conditions (“Terms“) of Our Website. Your use of the Website and any features and/or services available on the Website constitutes your agreement to these Terms and Privacy Policy. Therefore, please read this Privacy Policy carefully to ensure that you fully understand it before registering, accessing and/or using the Website.

Personal Data and Transaction Information and/or Data

Personal Data is about you that can be recognized, identified or identifiable individually or in combination with other information either directly or indirectly. Personal Data and Information and/or Transaction Data may include Personal Data and Information that are general and specific in accordance with applicable laws and regulations.

Collection of Personal Data and/or Transaction Data

You can provide your Personal Data directly when you register on our Website or when using the Services, and Transaction Data is obtained at any time you use the Services available on the Website.

We collect as much information as possible from various sources in accordance with applicable laws and regulations, including Personal Data and/or Transaction Data collected by Tugu Insurance Group of Companies, either new or historical data, so that We can always provide the best services to the Website users from time to time. You hereby agree and authorize (i) us to use the Personal Data and/or Transaction Data that you provide to us or the Tugu Insurance Group of Companies and (ii) for the Tugu Insurance Group Company to disclose, provide, transmit and share your Personal Data and/or Transaction Data to us. The provision of your Personal Data is voluntary, but if you do not provide your Personal Data to us correctly, We may not be able to provide the appropriate Services.

Use of Personal Data and/or Transaction Data

1. You hereby give express consent to us to use your Personal Data and/or Transaction Data for the use of the Website, our business and operational activities and other purposes including but not limited to:

o      Responding to questions, comments or complaints.

o      Communicating with you through various media such as in-app notifications, emails, telephones, short message services (SMS), in-app messaging / push notifications, and social media.

o      Marketing and promotion of our products/services, including announcements, promotional materials, greetings, our partners, sponsors and advertisers.

o      Processing your participation in any production, contest, game, promotion, poll or survey activities.

o      Understanding and analyzing patterns of use and sales of products and services related to needs and preferences.

o      Developing, improving and providing products and services that suit your needs.

o      Internal administrative processes such as auditing and taxation.

2. We make reasonable efforts to protect any of your Personal Data and/or Transaction Data. We always endeavor to improve the standard of protection for the Website. However, We are not liable for any losses arising from any loss of or damage to any of your Personal Data and/or Transaction Data occurring beyond our control. Therefore, we strongly recommend that you always update the data on your account and the software you use and do not disclose your account password to any party.

Provision and Disclosure of Personal Data and/or Transaction Data

You hereby expressly consent to us that for business and operational or other purposes, We may cooperate with third parties regarding the Use of your Personal Data and/or Transaction Data. Such third parties include but are not limited to:

• Research and marketing companies related to the promotion of our products/services.
• Companies that provide services related to information technology (including infrastructure, cloud computing, software, big dataanalysis and machine learning services, including data cleaning services, data insight)
• Companies that provide payment transaction processing services including payment gateway, fund transfer, electronic wallet, electronic money and other providers of payment system services relating to in-app transactions.
• Companies that provide other services and our partners in relation to Services, products and services offered in Applications.
• Professional advisors and external auditors, including legal advisors, financial advisors and other consultants.
• Government authorities, either those within or those outside the jurisdiction of the Republic of Indonesia in accordance with applicable laws and regulations.
• Other parties in accordance with the applicable laws and regulations.

Management and Security of Personal Data and/or Transaction Data

We highly value your Personal Data and/or Transaction Data and make reasonable efforts to protect any Personal Data and/or Transaction Data. We always endeavor to improve the standard of protection for the Website, however, We are not liable for any losses arising from loss of or damage to your Personal Data and/or Transaction Data occurring beyond our control. Therefore, We strongly recommend that you always update your Website account and software and do not disclose your Website account password to any party.

You hereby expressly consent to us that We may transmit, store, use and process your Personal Data and/or Transaction Data on servers located in the database designated by us. The database may be managed by a third party and/or located within and outside the territory of the Republic of Indonesia in accordance with the provisions of applicable laws and regulations. However, the Use of your Personal Data and/or Transaction Data in connection with the use of Applications will continue to be governed by this Privacy Policy in accordance with applicable laws and regulations. We will retain your Personal Data and/or Transaction Data until there is a special request and the data is no longer used, whereupon we will delete your account.

User’s Right to Update and Change Personal Data

You may change the Personal Data you have provided to us at any time, opt out of receiving communications from us and/or withdraw your consent to the Use of your Personal Data. You agree that the withdrawal of such consent may affect your access to Applications and/or Services that you may use. You may use the information in the Contact Us section to contact us regarding this.

Consent

By using our products and/or services, you hereby agree to the terms of your Personal Data and Information Management by us, and authorize us to collect, use, disclose, store and delete your Personal Data and Information in accordance with the provisions of the Terms of Personal Data Management.

Storage and Deletion/Destruction of Personal Data

Personal Data and Information storage is subject to the regulations applicable to each of our products and/or services, and in accordance with the provisions of applicable laws in relation to deletion of your Personal Data and Information, We will carry out the deletion action in the following events:

1. Not required for processing purposes.
2. Withdrawal of consent.
3. Request from you, to the extent that you no longer have any contract with Tugu Insurance.
4. Illegal Processing.

Deletion of your Personal Data and Information will be subject to the provisions of applicable laws and regulations. However, in such conditions as listed below, no Personal Data and Information may be deleted as requested:

1. Retention Period, Personal Data and Information must remain kept during the retention period as regulated by applicable laws and regulations.
2. Legal obligations and evidentiary purposes, for the purpose of complying with legal obligations, future evidentiary purposes, tax liabilities, audit processes, and accounting requirements, We may be required to retain relevant Personal Data and Information so far as you still use our products and/or services or in accordance with the time provisions set out in applicable laws and regulations.

We affirm that We will confirm that the deletion and storage of your Personal Data and Information are carried out in accordance with the provisions of applicable laws. We are committed to protecting your Personal Data and Information and treating your information with the utmost care.

User Agreement

By registering, accessing and/or using the Website, you are deemed to have read, understood and expressly agreed to our Privacy Policy as described above. You also represent and warrant that the Personal Data you provide to us is true, complete, lawfully obtained and that You have the full right to provide it to us.

We may change this Privacy Policy at any time by posting information about such changes on Applications. Continuing access and/or use of an Application and the absence of written notice to us of your objection to the changes made is a form of your acceptance and agreement to the changes to the Privacy Policy. Therefore, We encourage you to review this page periodically for the latest information on how the provisions of this Privacy Policy apply. You are responsible to always understand the changes We make from time to time.

You release, hold harmless the Company from any and all lawsuits, claims, liabilities, arising directly and indirectly from any losses resulting from Personal Data intercepted, accessed, stolen, disclosed, altered, or destroyed by unauthorized third parties, due to factors beyond the Company’s control and/or that are contrary to this Privacy Policy, applicable laws and regulations, including those resulting from your mistakes or omissions.

Law and Dispute Resolution

This Privacy Policy is governed by and construed in accordance with the applicable laws of the Republic of Indonesia and any dispute arising from this Privacy Policy will be resolved through the South Jakarta District Court.

We always adjust the provisions of the Privacy Policy to conform to applicable laws and regulations. In the event that there are provisions in the Privacy Policy that are not in accordance with the applicable laws and regulations, We will immediately make corresponding adjustment to conform to applicable laws and regulations.

Contact Us

You have the right to the correction and deletion of your personal data including further information regarding the use of the Website and transactions. If you need more information or have a complaint, you can contact the Company through PT Asuransi Tugu Pratama Indonesia Tbk. – Head Office, Wisma Tugu I Jalan H.R. Rasuna Said Kav. C8-9 Jakarta 12920 Indonesia, email calltia@tugu.com Phone 1500 458 available on the Website.