PRIVACY POLICY OF PT TOKIO MARINE LIFE INSURANCE INDONESIA

I.        INTRODUCTION

We, PT Tokio Marine Life Insurance Indonesia and DPLK Tokio Marine Life Indonesia (collectively referred to as "Tokio Marine Life Indonesia"), understand the importance of safeguarding the personal data of customers, policyholders, partners, and other stakeholders. This Privacy Policy is established with a commitment to ensuring that every use and management of personal data is conducted in good faith and in compliance with applicable laws.

The primary purpose of this Privacy Policy is to explain how Tokio Marine Life Indonesia collects, uses, manages, and protects the personal data provided by individuals associated with our products and/or services. We aim to create a safe and trustworthy environment for all parties involved in interactions with Tokio Marine Life Indonesia. This policy also provides guidelines to you regarding your rights and obligations related to personal data.

The scope of this Privacy Policy covers the practices of collecting, using, and disclosing personal data by Tokio Marine Life Indonesia in accordance with the prevailing laws in Indonesia. This policy includes information provided to us by customers, policyholders, business partners, as well as information we collect through our website. We encourage every individual associated with Tokio Marine Life Indonesia to carefully read this Privacy Policy to understand their rights and obligations regarding personal data.

We reserve the right to make changes to this Privacy Policy by updating the Privacy Policy page on our website. We highly recommend that you periodically check the Privacy Policy on our website, as the version available on our website always reflects the latest updates to our Privacy Policy compared to previous versions.

II.        COLLECTION OF PERSONAL DATA

A. Types of Personal Data Collected

We collect various types of personal data required for our business operations. This data includes:

• Personal and Contact Information: Such as full name, phone number, address, email, date of birth, gender, religion, employment information, health data and history, financial information, marital or family status information, education, and relevant identity copies related to our products and/or services.
• Family Members: Data related to family members.
• Products and/or Services: Information about the products and/or services you use, are interested in, and the payment methods you choose.
• Usage of Products and/or Services: History of application and payment of claims, along with related details.
• Information from Marketing Partners: Data related to products and/or services that you may not use but are managed by our marketing partners.
• Data from Third Parties: Information regarding insurance risks, pricing determinations, claims history, health data and history, and indications of suspected fraud, as well as publicly available information and information to help improve the relevance of our products and/or services.
• Fraud Information: Data related to fraud, debt, and theft, including ownership details and devices used in fraud.
• Health/Medical Records: Information about your health or medical records.
• Financial Details: Data regarding financial details, including salary, additional income, savings, tax information, expenses, and payment methods.
• Employment Status: Information about your employment status, position, department, and the institution or company where you work if relevant to our products and/or services.
• Residential Status and Citizenship: Information about your residential status and citizenship.
• Insights and Transactions: Insights about you and our customers obtained from customer analysis or profiles, as well as transactions involving third parties.

B. Sources of Your Personal Data

We will collect personal data from various sources, including:

1. Data You Provide: This includes information you provide directly, such as your personal data, and information you may provide about your family members, associates, insured individuals, dependents, or beneficiaries of the products and/or services you apply for.
2. Usage of Products and/or Services: Personal data generated when you use our products and/or services.
3. Collaboration with Partners: Data we receive from insurance brokers, intermediaries, marketers, distributors, business partners, or other affiliates who collaborate with us in providing products and/or services to you after obtaining your consent.
4. Data from Tokio Marine Insurance Group: If you already have products and/or services from the Tokio Marine Insurance Group, have applied for one product and/or service, or have been a previous customer, we will access relevant data from our group companies.
5. Location and Online Data: This includes information we obtain through cookies, location services, IP addresses when you visit our website or mobile applications, or when you fill out contact forms within them.
6. Surveys and Questionnaires: Data you provide in surveys or questionnaires, as well as your contact details when you participate in surveys, investor conferences, or other events.
7. Other Sources: We may obtain data from various other sources such as lenders, directories, or publicly available information, including social media, the internet, news articles, and other sources.
8. Purchased or Contracted Data: Information we purchase or contract from third parties, including demographic data, vehicle details, claims history, fraud information, marketing lists, and information that can help us enhance our products and/or services.

C.        Purposes of Data Collection

In the collection and processing of your personal data, we will adhere to a number of underlying purposes for these processes as follows:

• Product and/or Service Administration: This includes, but is not limited to, the process of insurance application, policy issuance, insurance risk assessment, our company's operational activities, submission and handling of claims, insurance benefits/claims payments, and co-insurance needs, including handling claims arising from co-insurance.
• Reference Checks: We may conduct checks using agents, third parties collaborating with us, or publicly available information.
• Design and Improvement of Products and/or Services: Designing and providing insurance, financial, and related products for you. We also undertake the design and improvement of our products, provide value-added services, develop our business, and gain insights into how our products are used.
• Marketing: We will use your personal data to offer insurance, financial, pension fund, and other related products that we design and market.
• Contractual Obligations Fulfillment: We will use your personal data to fulfill contractual obligations that may arise in connection with products and/or services you request from us.
• Information Provision: Your data will be used to provide information you request from us, such as product updates or other information that may be of interest to you.
• Compliance and Legal Enforcement: We will process your personal data to comply with our legal obligations, enforce our rights arising from agreements involving you, and take legal action if necessary.
• Fraud Prevention and Detection: Your data will be used to prevent and detect fraud.
• Website Development: Data will be used to enhance the user experience and functionality of our website.
• Website Content: We will use your data to present the content of our website to you, including online training or employee performance review processes.
• Mergers and Acquisitions: In the context of mergers, divestitures, reorganizations, or the sale of our assets, personal data we hold may be transferred in accordance with applicable law.
• Others: Other purposes explained at the time of your personal data collection.

D.        Legal Basis for Data Collection

The collection and processing of your personal data are based on several legal bases outlined below:

• Contractual Fulfillment: We will collect and process your personal data due to the need to fulfill the contract you have with us or to take necessary steps before signing a contract. This includes information required to execute the products and/or services you have with us, such as payments, product delivery, or benefits you obtain from us.
• Legitimate Interest: We will use your personal data in our legitimate interests, including maintaining and developing our relationship with you, improving our products and/or services, and providing beneficial services to you. This also includes the use of data for internal purposes such as analysis, research, and product development.
• Legal Compliance: The collection and processing of your personal data will be done to comply with applicable legal obligations, such as tax requirements, financial regulations, and consumer protection laws.
• Your Consent: If we send direct marketing offers to you through electronic or non-electronic media, the processing of such data will be based on the consent you provide. You have the right to withdraw consent at any time.
• Automated Processing: If we carry out automated decision-making or create automated profiles, it will be done in accordance with applicable requirements and your rights to provide consent, object, or review such decisions.

We ensure that the collection and processing of your personal data comply with applicable legal bases and always strive to maintain the privacy and security of your data. If you have any questions or need further information about the legal basis for data collection, feel free to contact us.

E. Personal Data We Disclose and Purposes of Disclosure

In conducting our business operations and providing products and services, we may need to disclose your personal data to third parties. This is done in accordance with applicable privacy laws and for specific purposes. The following are categories of third parties that may receive your personal data and the underlying purposes of such disclosure:

1. Parties Related to Products and/or Services: Your personal data may be shared with third parties related to the products and/or services you have with us. This includes those collaborating with us in providing products and/or services or involved in the claims process or agreement settlement. Our interest is to ensure efficient services, timely claims processing, and fulfillment of our contractual obligations to you. These third parties may include insurers, insurance intermediaries, medical service providers, insurance companies, claims investigators, insurance claim administrator, administration service providers or relevant fund managers.
2. Authorized Parties: Your personal data may be shared with appropriate authorities, such as government agencies or courts, when compliance with legal obligations or court orders is required. This includes fulfilling tax requirements, financial regulations, or criminal investigations.
3. Security and Information Security-Related Parties: We may share your personal data with third parties assisting in fraud prevention and detection, as well as maintaining our information security. This includes parties handling security analysis, protection against cyber-attacks, and enforcement of security policies.
4. Business Partners: In some cases, your personal data may be shared with business partners collaborating with us in developing, marketing, or providing specific products and/or services. This is done in accordance with applicable laws, and the purpose is to support our business.
5. Third Parties for Marketing Purposes: If you have provided consent, your personal data may be used for marketing purposes. This includes contact through electronic or non-electronic media by carefully selected third parties, both in the context of our products and/or services and third-party products and/or services.
6. Entities within the Company Group: Your personal data may be shared with entities within our company group, including subsidiaries, affiliate companies, and companies under the same control or ownership. This is related to business management and internal administration.
7. Data Processing Parties: We may use external service providers to process personal data on our behalf, such as cloud computing service providers, IT service providers, analytics service providers, and others. All parties processing personal data must comply with applicable security and privacy standards.
8. Other Parties with Your Consent: In specific situations, your personal data may be shared with other parties only with your consent. We will seek your explicit consent before sharing data in this context.
9. Other Parties in Business Transaction Context: In scenarios involving mergers, acquisitions, restructures, reorganizations, dissolutions, or asset sales, the personal data we hold may be transferred to third parties as part of the business transaction.
10. Other Parties for Special Purposes: Apart from the purposes outlined above, we may share your personal data with other parties in different situations explained to you during data collection.

F.        Retention of Personal Data

Your personal data will be processed as long as you are our customer at Tokio Marine Life Indonesia. When your customer relationship with Tokio Marine Life Indonesia concludes, the processing of your personal data will also cease.

Your personal data will be retained for a period of 10 (ten) years after the termination of the customer relationship, or longer if required by law or if there is an ongoing legal process.

G.        Reference Checks

We may utilize services from reference-checking agencies for personal data, such as the Population and Civil Registration Service, or access information available to the public. Our main purposes are to verify your identity, prevent fraud, and ensure compliance with rules regarding money laundering and the prevention of terrorism funding. These actions may involve checking your current or previous addresses. The results of these checks will be recorded and used as a reference in the future.

In situations where we lose contact with you, our agents may be used to verify your address, help us reconnect with you, and maintain the quality of our services.

H.        Use of Personal Data for Automated Decision-Making or Your Profiling

We, Tokio Marine Life Indonesia, and our business partners may use your personal data to make automated decisions that affect you or for other types of profiling, such as marketing profiles. This step is taken as long as it does not violate the law or have a significant impact on you as a Data Subject. These decisions are aimed at ensuring that we can provide relevant and beneficial products and/or services to you.

III.        RIGHTS OF YOUR PERSONAL DATA SUBJECT

As a personal data subject, you have the following rights related to your personal data:

a) Right to be Informed: You have the right to be informed about our identity, the legal basis for processing your data, the purposes of collecting and using your personal data, and how we ensure accountability regarding your personal data.

b) Right to Correction: You have the right to complete, update, or correct any errors or inaccuracies in your personal data in accordance with the purpose of processing that data.

c) Right of Access: You have the right to access and obtain a copy of your personal data that we hold.

d) Right to Erasure: You have the right to request the deletion, destruction, or cessation of processing of your personal data that is no longer relevant, subject to the conditions, exceptions, and prohibitions set by applicable regulations.

e) Right to Withdraw Consent: You have the right to withdraw your consent to the processing of personal data that you have provided to us.

To submit requests related to your personal data subject rights, please send an email to us through Customer Care at customercare@tokiomarine-life.co.id.

We will respond to your requests in accordance with the provisions stipulated by applicable regulations.

We would like to emphasize that Tokio Marine Life Indonesia will not discriminate against you as a result of exercising your personal data subject rights or filing complaints. This Privacy Statement will not limit your rights as a personal data subject under the regulations related to the protection of personal data in Indonesia.

IV. CONTACT US

If you wish to exercise your rights as described in the section "Rights of Your Personal Data Subject" or if you require information on other parts of this Privacy Policy, please contact us:

• Hotline: 15 000 86

• WhatsApp: 089 535 1500086

• Email: customercare@tokiomarine-life.co.id

• Address: PT Tokio Marine Life Insurance Indonesia 
  International Financial Centre Tower 2, Lantai 33A 
  Jl. Jenderal Sudirman Kav.22-23, Jakarta 12920

• Operational Hours: Senin - Jumat: 08.30 - 17.30 WIB