PT FREEDEAL BERKAT JABEZ
- Commitment to Respecting Consumer Personal Data and/or Information.
PT Freedeal Berkat Jabez(“FREEDEAL”) is committed to protecting and respecting Customer Personal Data and/or Information (“Personal Data”) under applicable law and regulations. This policy and procedures (“Policy”) describe the personal information FREEDEAL (“we” or “us” or “FREEDEAL” or “our”) collects and how we use that Personal Data in our business. This Policy also describes data protection rights. Our goal is the responsible and secure handling of Personal Data. We strive to achieve a proper and fair balancing of Customer legal rights with the benefits of our activities and our legal obligations and regulatory requirements.
- What is Personal Data?
Pursuant to Indonesia Financial Services Authority (Otoritas Jasa Keuangan/OJK) Regulation No. 1/POJK.07/2013 concerning Protection of Customer Financial Services Sector and Circular Letter No. 14/SEOJK.07/2014 concerning the Confidentiality and Security of Customer Personal Data and/or Information dated 20 August 2014, Personal Data shall be information that contains the following:
- For individual consumer
- Date of Birth and/or age;
- Telephone number; and/or
- Mother’s maiden name.
- For corporate consumer
- Telephone number;
- Composition of Board of Director and Board of Commissioner including the identity documents such as ID/passport/stay permit; and/or
- Composition of shareholder.
Pursuant to Regulation of the Minister of Communications and Informatics of the Republic of Indonesia No. 20 of 2016 concerning Protection of Personal Data in the Electronic System:
- Personal Data means particular individual data that are stored, maintained and kept for correctness and protected for confidentiality
- Particular Individual Data means any correct and actual information that relates to any individual and is identifiable directly or indirectly to be manipulated under the laws and regulations.
As used in this Policy, Personal Data for example, includes information we collect about insurance applicants, policyholders, beneficiaries, medical checkup participants.
- Personal Information from Others.
Personal information also includes personal information our third-party business partners and vendors and other FREEDEAL affiliates collect and provide to us. For example, we obtain such information from insurance, hospital/clinic, laboratory, claims investigators, witnesses, medical professionals, driving and vehicle licensing authorities, credit reference agencies vendor’s employer, and other third parties and service providers. We also combine information from other sources with information Consumer provide us.
- How We Collect Personal Data.
We collect Personal Data in many ways, including from information or documents submitted to us electronically or otherwise, information submitted through our Site, during online or telephone conversations, and at in- person meetings or through other communications.
- Providing Personal Data about Others.
If Consumer are providing personal information about another individual to us, Consumer must first inform the individual about the content of this Policy and any other supplemental or additional policies we have provided to Consumer (for a list of our supplemental and additional policies). Consumer must also, where possible, obtain permission from such individuals to share their personal information with us in accordance with this Policy and any other supplemental or additional policies.
- Basic Principles
- We will acquire Personal Information of c ustomers only to the extent necessary for our business in a lawful and fair manner. Furthermore, we will notify customers of, or announce, the purpose of use of their personal information, and use their personal information only for those purposes, unless required to do so under laws.
- We will not provide Personal Data of Customer to any third parties without consent of the customer in question, unless it is required under laws. Personal information will not be provided to third parties unless these data are required under laws.
- We will take proper information security measures while striving to prevent leaks, loss or damage of the personal data of customers. We will also ensure the necessary and appropriate oversight of the contractors to whom we may entrust personal data of customers.
- We will rigorously train and instruct employees in order to ensure the proper handling of the personal data of customers. We will also continuously review our management systems for protecting personal data and strive to improve those systems.
- We will immediately respond to any complaints or consultations regarding the handling of personal data. We will also respond properly to requests from customers for disclosure or revision, etc. of the personal data we retain.
- Handling of Anonymized Information
- FREEDEAL employs the following handling procedures when preparing anonymized information (i.e., personal information on individuals that has been processed, through means stipulated in laws and regulations, so that it is not possible to identify the individuals concerned or to restore such personal information):
- We process such information properly in accordance with standards stipulated in laws and regulations.
- We implement security measures to prevent leakage of information concerning the information that has been deleted and methods of processing used, in accordance with standards stipulated in laws and regulations.
- We disclose the items of information contained in such anonymized information.
- We do not act in ways that would identify the individuals concerned by the personal information on which such anonymized information is based.
- Providing of anonymized information.
- The Personal Data We Collect
If FREEDEAL obtains the Personal Information from another party and FREEDEAL intends to use the Personal Information for FREEDEAL activities, FREEDEAL is required to have in its possession a written statement affirming that the other party has obtained written consent from the person and/or group of persons to provide the personal data and/or information to any party, including the FREEDEAL.
- Policyholders and Claimants.
When Consumer or a third party on Consumer behalf applies for an insurance contract or other service or asserts a claim to recover under an insurance policy that Our Principle have issued, we collect information about Consumer and other relevant persons or entities that is necessary or appropriate for us to consider and review to carry out our business and comply with applicable laws and regulations. The information we collect may include Consumer name, contact information including email address, gender, marital and family status, date and place of birth, physical characteristics appropriate in the circumstances, educational background, employer details and employment history, skills and experience, professional licenses, memberships and affiliations, dates and causes of property damage, loss, theft, injury, disability or death, records of personal activities such as driving and details about a dispute, claim or proceeding involving Consumer, social security or national insurance identifier, passport number, tax identification number, driver’s license number or other government issued identification, financial information, credit history, medical history, current or previous physical, mental or medical condition, medical diagnosis, health status, injury or disability information, medical procedures performed or treatments given or personal habits such as smoking, alcohol consumption, prescriptions, information about criminal records or civil litigation history and other such information that appropriate with cooperation agreement contract is collected. We use this information as part of our decision-making process.
- Employees and Corporate Policies.
We also hold such personal information if Consumer are an employee or other beneficiary under a corporate policy taken out by Consumer’s employer.
- Use of Personal Data and the Legal Basis for Processing and Using It
- How We Use Personal Data.
We use Personal Data in many different ways in various aspects of our business and operations when Consumer seek to purchase a product or service, or benefit from our product or service. Personal Data will be used for different purposes if Consumer are a policyholder, insured or claimant under an insurance policy, witness or another individual with whom we have a relationship. The main purposes for which we use personal information include:
- Communicating with Consumer or verifying Consumer’s identity;
- Communicating with Consumer or Principle about our products or services, including managing complaints to government regulators and the handling of requests for data access or data correction or the exercise of an individual’s data protection or associated rights;
- preventing, investigating or reporting potential fraud, money laundering, terrorism, misrepresentation, or security incidents or sanctions violations or any crimes in accordance with applicable law or regulations;
- managing, reporting and auditing our business operations;
- researching, developing and applying risk management and statistical analyses;
- establishing, exercising or defending legal claims;
- protecting our business operations and those of our affiliates, business partners or Consumer;
- Enforcing the terms or conditions of legal contracts and pursuing available remedies and limiting our damages;
- meeting regulatory and compliance requirements; and
- responding to requests by governmental agencies or law enforcement authorities conducting an investigation or for reporting required in connection with our businesses or in accordance with all applicable laws and regulations, including sanctions requirements.
- Use of Consumer Information to Prevent Fraud and Money Laundering and for Anti- Terrorism.
As an organization in the business of management consulting, insurance channel distribution, we are required to use certain categories of information we collect about Customer (for example, any health data or criminal records data as part of a claim or political affiliations or criminal records data) for prevention of fraud, terrorist financing, money laundering or the prevention or detection of other unlawful acts where this is necessary for reasons of substantial public interest as defined by applicable laws or as otherwise authorized by applicable laws. To the extent, therefore, that applicable laws consider the use or processing of any data or information that we collect as necessary for the tasks we perform or in the substantial public interest, then we will collect and use the data for such purposes.
- Our Legitimate Business Interests
Where we rely on our legitimate business interests to justify the purposes for using Consumer personal information and where it is useful to provide Consumer with a more specific description of how we collect and use personal information. For the most part, however, our legitimate interests for using Consumer personal information will usually be:
- Pursuit of our business and commercial objectives;
- Compliance with applicable laws and regulations and our obligations to comply with the guidelines, standards and codes of conduct that apply to us in our business;
- Protection of our customers and employees and our own business, our shareholders and other parties to whom we are obligated or owe a legal duty;
- Analysis of competition in the market for our services or products, including research;
- Matters of necessary or important public interest such as anti-money laundering and terrorist financing laws and regulations and other laws aimed at preventing financial crimes; and
- Other justifications that may also apply depending upon the particular circumstances or the applicable law or regulation
- How We Share Customer Data
- Sharing Customer Information as Part of Our Business
For the purposes described in this Policy, we share Customer information in our business activities with:
- FREEDEAL affiliates. We share Customer information with other group companies for our business and for the FREEDEAL Group’s administrative and accounting purposes;
- Government authorities and law enforcement agencies;
- Government agencies and industry associates engaged in fraud prevention, antiterrorism, anti-money laundering or sanctions activities;
- Parties that have, or are interested in acquiring, a financial interest in the Insurance policy, Medical Services or other contract used in our businesses;
- Third parties that assist us in carrying out our business activities such as insurance, health service provider company, claims administrators, document and records management providers, claims investigators and adjusters, medical and health professionals, security professionals, property experts, engineers, construction consultants, financial advisers, accountants and actuaries, surveyors, loss adjusters, claims agents, experts, solicitors, private investigators and others that assist us in receiving, reviewing, confirming, auditing or contesting insurance or reinsurance claims or defending the interests of an insured or the reinsurer in an insurance or reinsurance matter;
- Central government registries;
- Other business partners, vendors or service providers that process information about Customer on our behalf, including information technology service providers that host or support our business and that have data about Customer and our businesses;
- Other parties in accordance with applicable laws and regulations;
- Parties in connection with a corporate or portfolio transaction, including a potential or actual sale, reorganization, or divestiture of a company, or the sale of any combination of our assets, products, services, or businesses;
- Parties in the course of a bankruptcy, dissolution or similar transactions or proceedings; and
- Otherwise with Consumer consent
- Protection of Consumer Information that is Shared
If we share Consumer personal information, we have appropriate non-disclosure and data security requirements in place to the extent required by applicable law and regulations
- Where Customer Give Us Consent
- Request for Consumer Consent
Consumer will be requested to give us consent to use Consumer information for the following purposes:
- To use Consumer contact details for the purpose of sending Consumer information about our products and services or other products and services provided by us;
- For other specific purposes in which we request or use the information for the purpose that is explained at that time.
- Written Consent
The procedure for written consent from Consumers may be expressed in forms that include but are not limited to:
- Option to agree or disagree; or
- Affix a mark indicating consent.
in the document and/or agreement for the product and/or services.
- Fraud Prevention, Anti-Terrorism and Anti- Money Laundering and Sanctions Compliance (PPATK)
- Sharing Information to Prevent Fraud, Terrorism, Money Laundering and Other Criminal Activities.
Consumer information is also used for the following purposes:
- To confirm, verify or share details about underwriting information or claims information;
- To ensure we have not been given incorrect, false or inaccurate information and to prevent potential or actual fraud or other illegal activity (we will also note this in the appropriate record or file we keep); or
- To comply with an applicable law or regulation or the order or requirements of a governmental or legal authority or agency that has jurisdiction over us.
- Sharing Consumer Information with Law Enforcement and Other Government Agencies
Law enforcement and other governmental agencies access and use the information shared in these circumstances for law enforcement and other governmental purposes.
- International and Global Transfers
- How Personal Data is Transferred Around the Globe
The global nature of our business and the services we provide require us to transfer around the globe the personal information we collect.
- Why We Transfer Personal Data Around the Globe
Request additional data/information.
- Data Protection When We Transfer Personal Data Around the Globe
When transferring such information, we comply with the applicable laws and regulations concerning the required protection of such information, including the applicable laws and regulations of such country.
- Access and Other Right
- Request for Consumer Personal Data and Consumer Rights to Correct, Restrict or Erase It and Withdraw Consumer Consent.
Consumer are entitled to ask us for a copy of Personal Data, to correct it, erase it or restrict its processing, and to ask us to transfer some of this information to other organizations. Consumer also have rights to object to some processing and, where we have asked for Consumer consent to process Personal Data, to withdraw this consent.
Consumer have the right to correct, restrict or erase and withdraw the consent at any time by using the Contact details described in point N.
- When Consumer Are Required to Provide Personal Data
If we require personal information to comply with applicable legal or contractual obligations, then Customer must provide such information. If such information is not provided, then we will not be able to consider Consumer application for our products or services or manage Consumer claim or satisfy obligations placed on us. In all other cases in which information is not required by us to perform our obligations or provide the requested service, then providing the requested personal information is optional.
- Security and Retention
- Measures to Protect Consumer Information.
We use appropriate, feasible information security and legal measures and technology where necessary to protect Consumer personal information, including firewalls and encryption that comply with applicable data protection laws. As most of the personal information and data that we hold is stored electronically, we have implemented appropriate measures to secure it. We have procedures in place at our premises to secure the hard copy records. We regularly train our staff who have contact with personal information and data on proper data protection and information security. When we engage a third party to collect or otherwise process personal information on our behalf, such third parties are required to protect the confidentiality and secure such personal information in accordance with their contractual obligations to us.
- How Long We Retain Personal Information.
We will keep Customer personal information for as long as necessary to fulfil the business purposes for which we need it or to comply with applicable law and regulations. The precise period of time will depend upon the purpose for which we hold Customer information. As a regulated organization, there are laws and regulations that apply to us that set out a minimum period of retention of personal information and data. We will, therefore, hold personal information and data, for a period of time that is at least necessary to comply with applicable law but may be longer if holding it is necessary in our business (for example, for an insurance policy or for claims handling)
- Consumer Suspect Consumer Information is Not Secure or Has Been Compromised.
We have to inform Consumer that if, at any time, Consumer have reason to believe that Consumer personal information with us is not secure or has been compromised, then please immediately notify us.
- Procedures for Disclose
Once we have received a request, we will confirm and investigate the details of the request. A response will be made to the person in writing.
When the request has been made by a proxy, the response will be made to that proxy. We may be unable to respond to a request if a response to a Request for Disclosure, etc. is likely to harm the life, body, property, or any other rights or interests of the person in question or a third person, seriously impede the proper execution of our businesses, or violate other laws or ordinances. In this case, we will respond with an explanation as to why we cannot fulfill the request.
As noted above, consumer can prevent Google Analytics and any other such service providers from recognizing Consumer on return visits to our sites by disabling cookies in Consumer browser. Google, for example, provides an “opt-out” tool that must be installed in Consumer browser. According to Google, this tool is intended to prevent Consumer browser from making Consumer site activity available to Google Analytics. The Google Analytics Opt-out Browser Add-on is available at https://tools qooqle.com/dIpaqe/qaoptout. We are, however, not responsible for this tool. If Consumer choose to use it or go through the opt-out process, Consumer do so at Consumer own risk.
- Access to other sites from our site.
When our sites contain links to third party websites, If Consumer follow links to these websites, please note that these websites have their own privacy policies over which we have no control.
- Information About Children Under 18.
We do not knowingly collect personally identifying information from children under the age of 18. If we learn that we have collected such information from a child under 18, the information will b e deleted from our database as soon as reasonably possible.
- Changes to this Policy
We will, from time to time, determine that changes in this Policy are prudent or required by changes in applicable law. If any such change is made, it will be posted on our Site. If required by applicable laws, we will provide reasonable notice by other means of communication. The applicable version of this Policy that will apply to our use or processing of information will be the version of this Policy in effect at the time the information is actually used or processed.
- Contact Us
If you have any questions regarding this Policy or our data collection practice or you wish to exercise any of our rights under applicable data protection laws, please contact us at:
PT Freedeal Berkat Jabez (Freedeal Insurance Solution)
The Centro Metro Broadway A/38 Jl. Pantai Indah Utara 2 ,
PIK Kapuk Muara, Penjaringan, Jakarta Utara 14460, Indonesia