PT. Eastspring Investments Indonesia Privacy Notice

We, PT. Eastspring Investments Indonesia, take the privacy and protection of your personal data seriously as in accordance with the current prevailing laws and regulations.

So, we’ve set out the below information about our processing of your personal data, what rights you have, and how you can get in touch if you want to know more.

When we say “personal data”, we mean information about you, such as your name, date of birth and contact details. We collect personal data from you that is necessary for us to either provide you with the product or service you’ve requested or to comply with prevailing laws and regulations and/or contractual requirements. Unfortunately, if you’re unable to provide certain personal data which is necessary for us to provide our products and/or services to you, we will not be able to provide you with those products and/or services.

When we say “you” or “your” in statements below, we mean “data subjects” from whom we collect, process and store personal data. These data subjects are representatives, directors and/or authorised signatories of our Institutional Clients; representatives, directors and/or authorised signatories of our vendors; or retail clients who have invested in our funds.

We may change this Privacy Notice from time to time by updating our Privacy Notice page on our website. We encourage you to check our Privacy Notice from time to time on our website, as the version of our Privacy Notice which is displayed on our website takes precedence over all previous versions of our Privacy Notice.

Part A – Personal Data We Process

  • personal and contact details, such as title, full name, contact details, and contact details history; and/or
  • travel document information; and/or
  • your date of birth, place of birth (or country of establishment), gender, age; and/or
  • your nationality, identity card number, tax identity number, tax residency and/or your institutional legal documents copies and details (if relevant to the product or service); and/or
  • your residential address, email address, and phone number; and/or
  • details of beneficiaries and minor beneficiaries of our products or services; and/or
  • 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
  • bank account information (if relevant to the product or service). For example, bank account name, branch address and bank account number; 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
  • products and services, you hold with us, as well as those you have been interested in and have held and the associated payment methods used; and/or
  • analysis of data relating to marketing made to you, including history of communications and whether you open them or click on links; and/or
  • information about your use of products or services held with our Marketing Partners, such as insurance policies, mortgage, savings or financial services and products; and/or
  • information we obtained from third parties, including information about insurance risk, pricing, claims history, instances of suspect fraud and usage history; and/or
  • personal data which we obtain from Credit Reference Agencies and Fraud Prevention Agencies, Sanction Screening provider, including public (for example, defaults) and shared credit history, financial situation and financial history; and/or
  • criminal records information, including alleged offences; and/or
  • financial details about you, such as your salary/revenue and details of other income, details of your savings, details of your expenditure, and payment method(s); and/or
  • information about your employment status (if relevant to the product or service and if relevant to the status belongs to the Beneficial Owner and/or Key Management Personnel); and/or
  • insights about you and our customers gained from analysis or profiling of customers; and/or
  • third party transactions; such as where a person other than the account holder uses the service, information about that person and the transaction; and/or
  • any other relevant personal data as required during the onboarding and/or any other data renewal process.
Part B – Where We Get Your Personal Data

We will collect personal data from the following general sources:

  • from you directly, and any information from family members, associates or beneficiaries of products and services; and/or
  • information generated about you when you use our products and services; and/or
  • from a distributor or other intermediary (for example, agents, distributors, business partners) who we work with to provide products or services or quote to you; 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
  • cookies, location services, IP addresses when you visit our website or mobile app or when you fill up contact us forms within our website or app; and/or
  • third parties such as agents, vendors, custodian bank, financial institutions, courts or public records; and/or
  • questionnaire and contact details when you attend surveys, investor conferences, roadshows or when you update contact us form on our website; and/or
  • 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

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:

 

Purpose Legal basis for processing
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. Necessary for the performance of our contract with you or in order to take steps prior to entering into a contract with you.
Carrying out checks using agencies such as credit reference agencies, sanction screening provider, tracing companies, or publicly available information (see Part D for more).
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).
Keeping your information on record and carrying out other internal business administration.
Complying with any prevailing laws and regulations or other legal requirements. Compliance with our legal and regulatory obligations.
Design and provide you with insurance, financial and related products and services. Our legitimate interests in designing and improving our products, provide value added services, developing our business and gaining insight into how our products are used.
Conduct research and statistical analysis (including use of new technologies).

 

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.

Who We Share Your Personal Data With and Why

We will share your personal information within the Eastspring Investments and Prudential plc group and to our financial business partners and third party service providers (including without limitation lawyers, bankers, accountants, financial institutions [including custodian bank, 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), medical bill review companies, claims investigations companies, industry associations and federations, your investment holder, professional advisors, researchers, credit reference agencies, debt collection agencies, 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.

We Keep Your Personal Data for A Set Amount of Time

Your personal data will be stored either for as long as you are our customer and for a period of five years after the end of the customer relationship, or longer if required by prevailing laws and regulations. There may be specific circumstances where it is necessary for us to retain your personal data for longer (such as when a dispute arises).

Part D - Reference Checks

For certain products, we may use approved credit reference agencies, sanction screening provider, tracing companies, financial intelligence unit, non-public and/or publicly available information, to help us to check your identity, as well as to prevent fraud and money laundering; this may include checks on your current or previous addresses. Results of these may be recorded for future reference.

These checks may also be carried out for a fund investor or person(s) that you provide personal data on. Should we ever lose contact with you, we may use these agencies to verify your address to help us get back in touch.

Any transfer of your personal data will always be done securely.

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 or services, 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 – You Are in Control

When it comes to how we use your personal data, you have the rights to:

  • request a copy of your personal data (we have the rights to charge a reasonable fee to complete this request); and/or
  • request that we correct anything that is wrong, or complete any incomplete personal data; and/or
  • request us to delete your personal data if it is no longer needed for the purposes set out in Part A or if there is no other legal basis for the processing; and/or
  • complain to a data protection authority or another independent regulator about how we are using it.

If you currently reside in EU jurisdiction, additional rights under General Data Protection Regulation (GDPR) may apply. As such, you may:

  • ask us to delete your personal data if it is no longer needed for the purposes set out in Part A or if there is no other legal basis for the processing; and/or
  • object to us using your personal data for direct marketing (including related profiling) or other processing based on legitimate interests; and/or
  • request us to provide a copy of your personal data in a structured and commonly used format in certain circumstances; and/or
  • limit how we use your personal data or withdraw your consents (including automated decision making) you have given for the processing of your personal data.

If you want to exercise your rights, or would like an explanation about these rights, we have explained how you can get in touch in the Contact Us section.

If you do need to speak to us, it will be useful to mention that the data controlleri of your personal data is PT. Eastspring Investments Indonesia. 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 H – 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 I – 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 G 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

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, reinsurers, investment managers, agents (and other stakeholders), scheme advisors, introducers, custodian, selling agent and any other selected third party financial and insurance product providers, and our legal advisers.

Distribution Partners means our service providers, intermediaries (and other stakeholders), scheme advisors, introducers, selling agents and any other selected third party financial and insurance product providers.

i Data controller- We will provide an electronic information (not paper records) that we hold and only that which you provided to us – we will not provide the results of any processing carried out on the data.