PT. Eastspring Investments Indonesia Privacy Notice
Last updated: January 31 2025
Introduction
We, PT. Eastspring Investments Indonesia ((“we “ or “The Company”), a limited liability company established under the laws of the Republic of Indonesia and engaged in asset management , take your privacy and protection of Personal Data seriously.
We e are committed to safeguarding the privacy and security of your personal data.
This Privacy Notice explains how we collect, use, process, and protect your personal data, in accordance with the relevant regulations and applies to all our institutional and retail clients. Retail client data is primarily collected via distribution partners, such as banks and online platforms, while institutional client data is directly collected through face-to-face meetings or virtual channels. The term "You" in this Privacy Notice refers to all owners of Personal Data (data subjects) who have used and/or will use our Products/Services, employees, agents, marketers, individuals who promote our products, vendors, Business Partners, visitors, and users of our website/app/electronic system, as well as any third parties to whom this Privacy Notice applies.
As (and we act as) a Personal Data Controller, we hereby establish and notify the policy and terms regarding the collection, processing, analysis, storage, correction, updating, display, publication, transfer, dissemination, disclosure, deletion, or destruction of your Personal Data, in accordance with the principles of Personal Data protection ("Personal Data Processing"). This notice also outlines your rights and how you can contact us for more information.
When we refer to "Personal Data," we mean data about you that is identified or identifiable, either independently or in combination with other information, directly or indirectly, as referred to in the Applicable Regulations. The Personal Data we process is as specified in Section A of this Privacy Notice. We process your Personal Data necessary for providing the products or services you request to fulfil an agreement (including employment contracts, marketing agreements, or cooperation agreements) or for legal and regulatory compliance ("Products/Services"). As a consequence, we will not be able to provide you with the Products/Services if you do not provide certain Personal Data necessary for us to offer our Products/Services.
This Privacy Notice was last updated in January 31, 2025, and is effective as January 31, 2025
Updates to this Privacy Notice will be communicated as outlined Part H: Updates to this Privacy Notice.
Part A – Personal Data We Process
- Identity Data: Name, date of birth, place of birth (or country establishment) gender, nationality, passport, tax identity number, tax residency and/or your institutional legal documents copies; contact information (including bunot limited to residential address, email address, and phone number).
- Financial Data: Account numbers, income details, and transaction records.
- Employment Data: Occupation and employer details (if relevant to services).
- details of beneficiaries’ marital status, detailed information of family members (if relevant to the product or service); and/or
- your religion information; and/or
- AML and Sanction Screening Data: For clients, staff, vendors, and third parties, we may collect data for identity verification and compliance checks.
- Communications Data: Emails, call logs, and meeting records.
- Sensitive Data: Only processed with explicit consent or as required by law.
- details of beneficiaries
- marital status, detailed information of family members (if relevant to the product or service); and/or
- your religion information; and/or
- your educational background, your occupation information, and range of your annual income; and/or
- records of your contact with us such as via the phone number of our customer service centre and, if you get in touch with us online using our online services or via our smartphone app, details such as your mobile phone location data, IP address and MAC address; and/or
- information we obtained from third parties, related to criminal records or suspected violations of the law, including fraud, debt, theft, money laundering, terrorism financing, proliferation financing of weapons of mass destruction, sanctions, suspected fraud or theft, and details of any device used for fraud;
- any other relevant personal data as required during the onboarding and/or any other data renewal process.
- Any sensitive data only processed with explicit consent or as required by law.
We will collect personal data from the following general sources:
- Direct Interactions: Meetings, video conferences, or communications with us.
- Third Parties or Intermediaries: Banks, securities brokerage online platforms, vendors, Kustodian Sentral Efek Indonesia (KSEI) or public sources like directories.
- Cookies and Analytics: cookies, location services, IP addresses data collected when you visit our website or mobile app or when you fill up contact us forms within our website or app and subject to cookie policy; and/or
- Eastspring Investments, Prudential Corporation Asia and Prudential plc group companies if you already have a product with them, have applied for one or have held a one previously; and/or
- questionnaire and contact details when you attend surveys, investor conferences, roadshows or when you update contact us form on our website; and/orr
- from other sources such as Fraud Prevention Agencies, Sanction Screening provider Credit Reference Agencies, other lenders, publicly available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies.
Part B.1 – Cookie Policy
Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you use the Site and also allows us to improve our Site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is stored on your computer's hard drive. You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser.
We use the following types of cookies:- Strictly necessary cookies: These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into our secure Site;
- Analytical/performance cookies: These allow us to recognise and count the number of visitors to our Site and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily;
- Functionality cookies: These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region); and
- Third Party Cookies: These cookies are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third-party cookie. These cookies may be set by third party providers whose services we have added to our pages.
By continuing to use the Site, you accept to the use of cookies as outlined above.
Part C - How We Use Your Personal Data and Why
Part C1. Purpose of Data Processing
We, PT. Eastspring Investments Indonesia, the Prudential Group, our Business Partners and Distribution Partners, will use the personal data you provide to us, together with other information, for the following purposes; compliance with applicable laws and
| No | Purpose | Legal basis for processing |
|---|---|---|
| 1 | Compliance with Legal and Regulatory Obligations | |
| We process your personal data to meet legal and regulatory requirements, including: | a) Indonesian PDP Law: Article 20 mandates data processing for compliance with legal obligations. | |
| Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance, including identity verification, transaction monitoring, and screening against sanctions lists. | b) OJK LAPMN (POJK 15/2023) | |
| Adherence to OJK LAPMN (POJK 15/2023), ensuring compliance with customer due diligence (CDD) and financial sector regulations. | c) OJK Regulation on Anti-Money Laundering and Terrorism Financing Prevention (POJK No. 8/2023) | |
| Implementation of OJK Regulation on KYC, Anti-Money Laundering and Terrorism Financing Prevention (POJK No. 8/2023), and Sanction Screening by applying a risk-based approach to prevent illicit financial activities. | d) OJK Anti-Fraud Regulation (POJK No. 12/2024): Requires financial institutions to implement anti-fraud strategies, necessitating the processing of personal data. | |
| Fraud detection and prevention, in compliance with OJK Anti-Fraud Regulation (POJK No. 12/2024), requiring financial institutions to implement fraud prevention mechanisms. | ||
| Tax and financial reporting obligations, as required by applicable local and international laws. | ||
| 2 | TContractual Obligation: | |
| We process personal data to fulfil contractual obligations, including: | Necessary for the performance of our contract with you or in order to take steps prior to entering into a contract with you, including: | |
| Providing and managing financial services, investment accounts, and transactions. | a. Indonesian Personal Data Protection Law (Article 21) | |
| Administering your investments as agreed under the contract. | b. OJK Regulation on Anti-Money Laundering and Terrorism Financing Prevention (POJK No. 8/2023) | |
| Administering your investments as agreed under the contract. | ||
| The administration of our products and services, including to enable us to perform our obligations to you and to provide any relevant services as discussed with you prior to any purchase of a product or service. | ||
| Carrying out checks using agencies such as sanction screening provider, tracing companies, or publicly available information (see Part D for more). | ||
| 3 | Legitimate Business Interests | Our legitimate interests |
| We process personal data for legitimate business operations, ensuring that such processing does not override your privacy rights. This includes: | We process personal data for legitimate business operations, ensuring that such processing does not override your privacy rights. This includes: | |
| Managing risks and preventing fraud in financial transactions. | Managing risks and preventing fraud in financial transactions. | |
| Improving and enhancing our products and services. | Improving and enhancing our products and services. | |
| Ensuring IT and cybersecurity protection to safeguard client data. | Ensuring IT and cybersecurity protection to safeguard client data | |
| Design and provide you with investment related products and services. | in designing and improving our products, provide value added services, developing our business and gaining insight into how our products are used. | |
| This is also aligned with Indonesian Personal Data Protection Law (Article 19) | ||
| Risk management to assess and mitigate operational risks | Necessary for risk management to assess and mitigate operational risks | |
| Provision of customer services - like to reply to a question or tell you that something is changing. | Necessary for the performance of our contract with you. After our contract is complete, our legitimate interests in maintaining and developing our relationship with you. | |
| Automated decision-making or profiling (see Part E for more). | ||
| MKeeping your information on record and carrying out other internal business administration. | ||
| 4 | Processing Based on Consent/strong> | |
| We process personal data only with your explicit consent for: | Indonesian Personal Data Protection Law (Article 19) How to Withdraw Consent: | |
| Direct marketing communications, including investment opportunities and promotions. | You may withdraw your consent at any time by contacting us at [client.communications@eastspring.com dan privacy.id@eastspring.com] | |
| Sharing personal data with third-party partners for non-regulatory purposes. | ||
| Processing sensitive personal data, where legally required. | ||
| 5 | Public Interest and Legal Claims | |
| We process personal data for: Public interest obligations, including financial security, fraud prevention, and national regulatory compliance. | Indonesian Personal Data Protection Law (Article 23) | |
| Legal claims, dispute resolution, and investigations as required by authorities. | ||
In addition, we, PT. Eastspring Investments Indonesia, the Prudential Group, our Business Partners and Distribution Partners, will use your personal data you provide to us, together with other information, to send you direct marketing offers by electronic and non-electronic means including by post, as well as sending you introduction to products and services from carefully selected third parties also by post. Please see part I for further details. Our legal basis for this processing is based on your consent.
Part C.2. Who We Share Your Personal Data With (including Cross Border Transfer) and Why
WBased on written consent from the data owner that is acquired during customer onboarding process. We will share your personal information within the Eastspring Investments and Prudential plc group; custodian banks of you’re the product, KSEI, screening agency and to our financial business partners and third party service providers (including without limitation lawyers, bankers, accountants, financial institutions brokerage and/or any other financial institutions which involves in any kind of legitimate financial transaction and/or recording process], and other third party service providers who provide administrative, telecommunications, computer, payment, printing, redemption or other services to us to enable us to operate our business either it is necessary from any risk management perspective and/or regulatory perspective whenever becomes compulsory as determined by any government body and/or regulator), , industry associations and federations, your investment holder, professional advisors, researchers, financial/health institutions and partnerships for any of the purposes set out in this Part C. If appropriate, we may also pass on your personal data to any relevant law-enforcement agency, financial intelligence unit, tax authority and/or any legal, regulatory or government bodies.
We may process your personal data in a country other than the one in which you reside. To the extent we transfer your personal data, we will use appropriate safeguards and comply with the prevailing laws and regulations of the country to which your personal data is transferred. Details of the safeguards we use are available on request.
Part C.4. We keep your personal data up to date (Data Accuracy)
We make reasonable efforts to ensure that the personal data we collectcollect and process is accurate, complete, and up-to-dateup to date. This includes:
- Proactive Measures: Periodically reviewing stored data for accuracy.
- Encouraging Updates: Encouraging data subjects to notify us of any changes to their personal information promptly.
- Verification: Validating the accuracy of key data during onboarding or service interactions.
Part D - Data Subject Rights
In accordance with the Indonesian PDP Law, when it comes to how we use your personal data you have the right to:
- Access Your Data: Request a copy of your personal data
- Correct Your Data: Rectify inaccuracies.
- Delete Data: Request the cessation of processing, deletion, or destruction of your Personal Data when no longer necessary for the purposes set out in this notice
- Withdraw Consent: Stop processing based on consent.
- Objection: Object to data processing for marketing or profiling and object automated decision making
- Right to delay or restrict data processing.
- Right to sue and receive
- Right to complain to EIID.
- Data Portability: Transfer your data to another provider (where feasible). Any transfer of your personal data will always be done securely.
For retail clients whose data is managed via banks or online platforms, requests will be processed through the respective distributor’s channels in accordance with OJK regulations and distribution agreements.
If you do need to speak to us, please be mindful that we may monitor or record calls or any other communication we have with you. This might be for training, for security, or to help us check for quality of our service.
Part E – We May Use Your Personal Data to Make Automated Decisions or Profile You
We, PT. Eastspring Investments Indonesia, the Prudential Group, our Business Partners and Distribution Partners, may use your personal data to make automated decisions affecting you or to conduct other profiling (for example, marketing profiling).
Part F – Use of Your Sensitive Personal Data
For certain products, we will need to process your sensitive personal data. To the extent that we need your explicit consent to process this kind of personal data in the manner described in Parts C, D, and E, we will provide details of this at the point of collection and seek your consent.
Part G – Security Measures
We implement robust security controls, including encryption, access restrictions, and secure data disposal, to safeguard your data, which includes Data Loss Prevention, Encryption, and monitoring. This may include:
- Encryption & Secure Storage – Client data is encrypted in transit and at rest to prevent unauthorized access.
- Access Controls – Only authorized personnel can access client data, with multi-factor authentication (MFA) where required.
- Cybersecurity Monitoring – Real-time monitoring, hacking, and unauthorized activities.
- Incident Response Plan – In case of a data breach or cybersecurity incident, affected clients will be notified in compliance with POJK 21/2023 and PDP Law.
Part H – Updates to this Privacy Notice
This Privacy Notice may be updated from time to time to reflect changes in regulatory requirements, our services, or internal policies.
When updates are made, we will notify individuals via appropriate channels, such as email, notifications on our website, or direct communication, depending on the nature of the change and applicable legal requirements. We encourage you to review the latest version of this Privacy Notice, available on our website, to stay informed of any updates.
By continuing to access and/or use our Products/Services or website/app/electronic system, including after any changes to the Privacy Notice, you agree to have read, understood, and accepted this Privacy Notice and all its changes.
Part H.1 – Notification of Data Changes Due to Corporate Transactions
In the event that we, PT Eastspring Investments Indonesia, undergoes a merger, separation, acquisition, consolidation, or dissolution of its legal entity, we are committed to protecting your personal data throughout the transition process.
If such a corporate transaction results in the retention, transfer, deletion, or destruction of your personal data, we will notify you in accordance with applicable legal requirements. This notification may be provided through email, website updates, or other appropriate communication channels.
Where necessary, we will seek your consent before transferring your personal data to another entity, ensuring that the new entity upholds the same or equivalent data protection standards.
Part I – Acting On Someone Else’s Behalf?
When you give us personal data about another person (or persons), you should have been legitimately appointed and authorised by such person to act on their behalf. This includes providing consent to:- our processing of their personal data and sensitive personal data (as we have explained in Parts A - G above); and
- you are getting any information protection notices on their behalf.
If for any reason you are concerned as to whether you are permitted to provide us with the other person’s information, please contact us at the email address below before sending us anything.
Part J – Direct Marketing
We, PT. Eastspring Investments Indonesia, the Prudential Group, our Business Partners and Distribution Partners, will still send you information by post about our and the Prudential Group’s products and services and carefully selected third parties.
Additionally, from time to time, we, PT. Eastspring Investments Indonesia, the Prudential Group, our Business Partners and Distribution Partners, would like to contact you by electronic means with details about our products, services and any special offers. We will only do this if you have consented to us for contacting you by electronic means.
And if you change your mind, and/or you would like to opt-out of receiving non-electronic direct marketing, it is easy to let us know. Just use one of the options in the Contact Us section.
Contact Us
If want to exercise your rights in Part D or if you require any other information about any other part of this notice, you can contact us in several different ways.
Write us at:
Client Service Officer
PT. Eastspring Investments Indonesia
Prudential Tower Lantai 23
Jl. Jend. Sudirman Kav. 79,
Jakarta 12910, Indonesia
Email us at:client.communications@eastspring.com and
privacy.id@eastspring.com
Contact us at:
Phone: +62 21 2924 5555
Fax: +62 21 2924 5566
Or visit us:
PT. Eastspring Investments Indonesia
Prudential Tower, Lantai 23,
Jl. Jend. Sudirman Kav. 79,
Jakarta 12910, Indonesia
Prudential Corporation Asia means Prudential Corporation Asia Limited.
The Prudential Group means Prudential Plc, Prudential Holdings Limited, Eastspring Investments Group and any other affiliates of Prudential Plc. Prudential Plc is not affiliated in any manner with Prudential Financial, Inc. a company with principal place of business is in United States of America or with the Prudential Assurance Company, a subsidiary of M&G Plc, a company incorporated in United Kingdom.
Business Partners means our service providers, accountants, auditors, IT service and platform providers, intermediaries, investment managers, agents (and other stakeholders), custodian, and our legal advisers.
Distribution Partners means our service providers, intermediaries (and other stakeholders), investment advisor , selling agents and any other selected third party investment product providers.