Privacy Statement

Your Personal Data is important to us. The purpose of this document ("Privacy Statement") is to inform you of how Great Eastern General Indonesia (GEGI) manages Personal Data (as further explained in the policy) which is subject to the Law Number 27/2022 on Personal Data Protection and Regulation of Ministry of Information of Republic of Indonesia Number 20/2016. Please take a moment to read this Privacy Statement so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us, enrolling or signing up for any products or services offered by us, you agree and consent to GEGI and their respective related group, as well as their respective representatives and/or agents ("Representatives") (the Companies and Representatives collectively referred to herein as "GEGI", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties to be processed in the relevant manner and for any of the purposes set forth in this Privacy Statement.

This Privacy Statement supplements but does not supersede nor replace any other consents you may have previously provided to GEGI in respect of your Personal Data, and your consents herein are cumulative and additional to any rights which any of the Companies may have at law to collect, use or disclose your Personal Data.

GEGI may from time to time update this Privacy Statement to ensure that this Privacy Statement is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Statement as updated from time to time on our website https://www.greateasterngeneral.com/id. Please check back regularly for updated information on the handling of your Personal Data.

1. Personal Data

In this Privacy Statement, "Personal Data" refers to data about an individual that is identified or can be identified separately or combined with other information either directly or indirectly through electronic or non-electronic systems.

Examples of such Personal Data you may provide to us include (not limited to) your name, ID card number, driver’s license, family registration, passport or other identification number, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

2. Collection of Personal Data

2.1 Generally, we collect Personal Data in the following ways:

1. When you submit any form, including but not limited to declaration, proposal or referral forms;
2. When you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
3. When you interact with our staff and other representatives, for e.g. via telephone calls (which may be recorded), letters, face-to-face meetings, digital platforms (including social media) and email;
4. When you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
5. When you are contacted by, and respond to, our marketing representatives and agents and other service providers;
6. When you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position;
7. When we receive references from business partners and third parties, for example, where you have been referred by them;
8. When your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
9. When we seek or receive information about you in connection with your policy, policy applications, claims or job applications, for example, from other insurers, insurance associations, hospitals, clinics, motor workshops, your ex-employer and the relevant authorities; and/or
10. When you submit your Personal Data to us for any other reason.

2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies and related technologies. We do not at our website automatically collect Personal Data, including your email address unless you provide such information or login with your account credentials.

2.3 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), including where you have named them as beneficiaries, or where you refer a third party to us for the purposes of us offering our products and/or services to that third party, by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. If there is a change to your personal particulars such as your residential/mailing address, email address or telephone number, please promptly update us. This ensures that you will continue to receive communications from us without disruption or delay. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 Generally, GEGI collects, uses and discloses your Personal Data for the following purposes:

1. Responding to, processing and handling your queries, complaints, feedback, suggestions and requests;
2. Manage the administration and operational business activities of the company and comply with internal policy and procedure;
3. Facilitating business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
4. Matching any Personal Data held which relates to you for any of the purposes listed herein;
5. Requesting feedback or participation in surveys, as well as conducting market research and/or analysis using data analytics, artificial intelligence and machine learning for statistical, profiling, prediction or other purposes for us to design our products, understand individual behaviour, performance, preferences and market trends, perform internal assessment to improve business processes, and to review, develop and improve the quality of our products and services offered to you, and participating in industry studies for public interest and education in addition to the purposes outlined in the foregoing;
6. Preventing, detecting and investigating crime, including detecting anomalies in payment systems to prevent fraud and money-laundering or terrorist financing, and analysing and managing commercial risks;
7. Managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
8. Project management;
9. Providing media announcements and responses;
10. Organizing promotional events;
11. In connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
12. Managing and preparing reports on incidents and accidents;
13. Complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation or conducting customer due diligence); and/or
14. Any other purposes relating to or reasonably necessary for any of the aforesaid.

These purposes may also apply even if you do not maintain any policy or relationship with us, or have terminated the policy or relationship with us.

3.2 In addition, GEGI collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

1. If you are a prospective customer or policy holder
   1. Reaching out to you (including by way of telephone calls) to provide recommendations to you as to the type of products and services suited to your needs;
   2. Where our staff or intermediaries have been assigned to service your account or portfolio, we may also use your telephone number(s) to contact you from time to time in order to take your instructions, and/or provide you with information, updates, or recommendations and/or in accordance with the terms and conditions of our agreement with you;
   3. Drafting insurance contract in accordance with the product agreed upon by you;
   4. Assessing and processing any applications or requests made by you for products and services offered by GEGI;
   5. Facilitating the continuation or termination of the insurance relationship or the daily operation of the services and providing policy holder servicing (including but not limited to responding to your individual requests, and providing customer satisfaction);
   6. Administering exceptional requests, including approvals or waivers;
   7. Carrying out policyholder reviews, for example, annual reviews of your portfolio;
   8. To establish your financial situation, risk profile, investment experience and investment objectives to help you consider the suitability of the products you have invested or intend to invest;
   9. Assessing the relevant risk factors and determining the premium levels payable;
   10. Providing offers and promotions (including updates and upgrades) you are entitled to receive in relation to GEGI or co-branded products and services which you have applied for;
   11. Customer outreach and relationship management;
   12. Archival management (including but not limited to warehouse storage and retrievals); communicating with you (including by way of telephone calls) in relation to your policy and informing you of updates to the policy benefits, terms and conditions and providing administrative information, including for the purposes of servicing you in relation to the products and services offered to you;
   13. Reinsuring risks with other insurers;
   14. Administering, maintaining, managing and operating the products and services offered to you, including reinsured products by other companies and government financing programmes;
   15. Sending updates and administrative notices to you in relation to the products and services used by you, including notification of maturity of payments and maturity of policies;
   16. Underwriting policy risks and facilitating underwriting and reviewing claims history, whether with GEGI or otherwise;
   17. Collecting premiums and debt collection;
   18. Assessing and processing of any claims and payments arising under your policy including by requesting from motor workshops information such as your claim/police; and/or
   19. Any other purposes relating to or reasonably necessary for any of the aforesaid.
       
       
2. If you are a beneficiary, or an appointed representative of a particular policy (including but not limited to a mandate holder or a power of attorney), or an insured member of group insurance policies
   1. Assessing and processing any applications or requests made by the policyholder for products and services offered by GEGI;
   2. Reinsuring risks with other insurers;
   3. Administering, maintaining, managing and operating the products and services offered to the policyholder, including reinsured products by other companies and government schemes and financing programmes;
   4. Underwriting policy risks and facilitating underwriting and reviewing claims history, whether with GEGI or otherwise;
   5. Collecting premiums and debt collection;
   6. Assessing and processing of any claims and payments arising under your policy including by requesting from motor workshops information such as your claim/policy; and/or
   7. Any other purposes relating to or reasonably necessary for any of the aforesaid.
      
      
3. If you submit an application to us as a candidate for an employment or representative position
   1. Processing your application including pre-recruitment checks, such as in relation to sanctions and criminal records;
   2. Administration of due diligence checks and verification checks including assessing whether you meet the fit and proper criteria and carrying out Anti-Money Laundering and Countering the Financing of Terrorism and identity verification checks;
   3. Providing or obtaining employee references and for background screening/vetting;
   4. Facilitating and conducting interviews;
   5. Assessing your suitability for the position applied for;
   6. Communicating with you as required by GEGI to comply with its policies and processes, including for business continuity purposes;
   7. Verification staff referrals; and/or
   8. Any other purposes relating to or reasonably necessary for any of the aforesaid.

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in delays in the processing of your application, or our inability to process your application.

4. If you are an external service provider or vendor outsourced or prospected by GEGI
   1. Managing project tenders or the supply of goods and services;
   2. Conducting checks for compliance and risk management purposes;
   3. Processing and payment of vendor invoices; and/or
   4. Any other purpose relating to or reasonably necessary for any of the above.

3.3 In addition, where permitted under the prevailing regulations, GEGI may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data):

1. Providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;
2. Matching personal data with other data collected from time to time for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by any of the companies or other third parties;
3. Sending you details of products, services, special offers and rewards, either to our customers generally, or which the companies have identified may be of interest to you; and/or
4. Conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for the companies to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences or profile.

3.4 If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, GEGI may contact you using such telephone number(s) (including via voice calls, text, or other means) with information about our company news, products and services (including discounts and special offers).

3.5 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4. Disclosure of Personal Data

4.1 GEGI will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided to and processed by the following entities or parties, for the purposes listed above (where applicable):

1. GEGI's related corporations;
2. Companies providing services relating to insurance and/or reinsurance to GEGI;
3. Where relevant, surveyors, loss adjusters, private investigators, motor workshops, hospitals or clinics in connection with the underwriting of policy risks or claims;
4. Associations of insurance companies, including the general insurance association Indonesia;
5. Agents, contractors or third party service providers who provide operational services to GEGI, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, investigator or other services to GEGI;
6. Vendors or other third party service providers in connection with products and services offered by GEGI;
7. Dispute resolution centres such as the Alternative Disputes Resolution Institution-Financial Industry Sector (LAPS-LJK);
8. Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
9. To your banks, credit card companies and their respective service providers in regards to payment of products that you have chosen;
10. Third party referrers;
11. Our co-brand and other business partners;
12. External business and charity partners in relation to corporate promotional events;
13. Our professional advisers such as our auditors and lawyers;
14. Relevant government regulators or authority or law enforcement agency to comply with any laws, rules and regulations or schemes imposed by any governmental authority such as the Financial Service Authority, the Ministry of Manpower, the Ministry of Information; Financial Transaction Reporting and Analysis Center (PPATK) and/or
15. Any other party to whom you authorise us to disclose your Personal Data to.

5. Other Bases for Handling Your Personal Data

5.1 In addition to and without limiting the consents you have provided to our collection, use and disclosure of your Personal Data for the purposes set out elsewhere in this Privacy Statement, where permitted by applicable law, GEGI may also in accordance the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below including without consent, where we meet the requirements of applicable law:

Legitimate Interests

We may collect, use and/or disclose your Personal Data without your consent for the purposes which we may notify you from time to time, where in the legitimate interests of GEGI or another person, including without limitation the purposes as notified to you above in paragraphs 3.1 and 3.2, of this Privacy Statement, but not for sending you direct marketing messages unless you have otherwise provided your consent.

6. Data Security

6.1 GEGI will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.

6.2 While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

6.3 If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches related to unauthorised and/or fraudulent use of your username and password.

7. Anti-Spam

7.1 If you receive spam messages and want to report it to us, please forward the message you have received to wecare-id@greateasterngeneral.com.

8. Third-Party Sites

8.1 Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. You should review the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

9. Contacting Us - Questions, Feedback, and Requests relating to your Personal Data

9.1 If you:

1. Have any questions or feedback relating to your Personal Data or our Privacy Statement, including without limitation our reliance on legitimate interests and/or deemed consent bases of collecting, using, and/or disclosing your Personal Data as described in this Privacy Statement; or
2. Would like to withdraw or delay your consent to any use of your Personal Data as set out in this Privacy Statement; or
3. Would like to obtain access and make corrections to your Personal Data records; or
4. Would like to object, limit or delay the processing to your Personal Data; or
5. Would like to request a correction, destruction or deletion of your Personal Data,

please contact GEGI as follows:

Email: wecare-id@greateasterngeneral.com

Call: (021) 5723737 (working hours)

Write in:
Data Protection Officer
PT Great Eastern General Insurance Indonesia
MidPlaza 2, 23rd Floor
Jalan Jenderal Sudirman Kav.10-11
Jakarta 10220, Indonesia

9.2 Please note that if your Personal Data has been provided to us by a third party (e.g. a policyholder who has nominated you as beneficiary), you should contact such party directly to make any queries, feedback, and access and correction requests to GEGI on your behalf.

9.3 You may refuse to give, or may withdraw, your consent for us to collect, use or disclose your Personal Data and/or your insured persons' Personal Data as provided under the Act by giving us reasonable notice, so long as there are no legal or contractual restrictions preventing you from doing so. For example, you may withdraw your consent for your Personal Data being used for marketing purposes if this withdrawal will not affect our ability to provide you with the products and services that you asked for or have with us.

9.4 You may request for removal of your Personal Data in GEGI upon termination of your policy (right to erasure), so long as there are no legal or contractual restrictions preventing you from doing so.

9.5 However, if you withdraw your consent for us to use your Personal Data for any purposes which we regard as necessary to provide you products and services supplied by or through us (such as for example, matters relating to the servicing and administration of your insurance policy), this may affect our ability to provide you with such products and services.

10. Governing Law

10.1 This Privacy Statement and your use of this website shall be governed in all respects by the laws of Republic of Indonesia.