Privacy Notice

1. INTRODUCTION

PT Asianet Media Teknologi ("Asianet" or "We", "Us") is a telecommunications technology company incorporated in Indonesia. Asianet is the data controller of all Personal information ("Personal Data") collected from data subjects as covered in this Notice, unless otherwise stated.

The following Privacy Notice explains how We acquire, collect, store, control, use, process, analyze, correct, update, display, announ, transfer, disclose, delete and/or destroy and protect Your Personal Data ("Processing Personal Data" or "Processing Personal Data").

In carrying out our operational activities, We are always committed to protecting the Personal Data of Asianet-related parties, including the Personal Data of Asianet's customers, workers, contractors and business partners.

A. Declaration and Consent

By agreeing to the Privacy Notice, the Party providing the Personal Data (hereinafter referred to as "you" or the "Personal Data Subject") acknowledges that you have read and understood this Privacy Notice and agree to all of its terms. In particular, You agree and consent to Us to Process Your Personal Data in accordance with this Privacy Notice.

If you provide Us with Personal Data relating to another individual (such as Personal Data relating to your spouse, family member, friend, worker, buyer or other party), then You represent and warrant that You have obtained consent from that individual, and hereby consent on behalf of that individual, to Our Processing of their Personal Data. We may ask you for proof of such consent at any time.

You may withdraw Your consent to any or all Processing of Your Personal Data at any time by providing Us with reasonable notice in writing using the contact details set out in this Privacy Notice. You must understand and acknowledge that upon withdrawal of Your consent will result in the termination of the service, deletion of your account or termination of Your contractual relationship with Us, with all rights and obligations arising to be fully fulfilled. Upon receipt of the withdrawal of consent from you, We will inform you of the possible consequences of such withdrawal so that you can decide whether you still wish to withdraw consent. Please note that for users of Our Services, if you choose to withdraw consent, We may still send you non-promotional messages, such as receipts, bills or information about your Account (as relevant).

B. Enforcement of Notification

This Privacy Notice applies to Personal Data that We collect, obtain, process or process, analyze, store, correct, update, display, anclose, transfer, disclose, delete or destroy, and/or protect at the time You:

• Conduct business with Asianet, either as a contractor, vendor, or Asianet business partner.
• Become an Asianet customer through products or services provided by Asianet, use the application, visit Asianet facilities and/or websites and derivatives.
• Works for Asianet.

If there is a specific Privacy Notice that governs a particular product, service, engagement or activity, the terms of that particular Privacy Notice will apply and read in conjunction with this Privacy Notice to the extent relevant.

This Privacy Notice should be read in conjunction with the terms and conditions, agreements, or other documents that apply to certain products, services, or legal relationships with Us, as these documents may contain additional provisions, disclosures, and information that specifically govern the processing of Personal Data in the relevant context.

2. BASIS FOR OUR PROCESSING OF PERSONAL DATA

In carrying out its operational activities, Asianet is the controller of your Personal Data that collects Personal Data on a lawful basis based on laws and regulations, and will depend on the type and purpose of the collection of Personal Data.

In general, We collect and Process Personal Data based on one or more lawful processing bases as stipulated in applicable laws and regulations, including:

• The consent you give to Us, whether mandatory or optional, as described in this Privacy Notice.
• The performance of contractual relationships and the provision of products and/or services to You, including but not limited to the provision of network access and availability, customer account management, payment and billing processing, and the performance of other operational activities necessary to fulfill Our commitments to You.
• Fulfillment of legal obligations and compliance with applicable laws and regulations, including obligations imposed on Us as a Personal Data Controller.
• The exercise of legitimate interests, as long as such processing is necessary to support business activities, operations, security, fraud prevention, service improvement, or other legitimate purposes, while taking into account the balance between Our interests and Your rights and freedoms as a Personal Data Subject.

3. HOW WE COLLECT YOUR PERSONAL DATA

Asianet may collect Your Personal Data through various interactions with Us, including when you:

• Use products, services, networks, applications or platforms provided by Asianet.
• Participate in promotional activities, loyalty programs, surveys, or marketing activities organized by Asianet.
• Contact customer service by phone, email, electronic media, or in-person visits to obtain services, submit questions, or make complaints.
• Access or interact with the Asianet website, including through online forms, digital services, or technologies such as cookies.
• Provide consent for access to device information, network usage, or location data in accordance with applicable terms.
• Respond to communications We send, including via email, SMS, questionnaires, surveys, or other means of communication.
• Register, update data, request information, or use available services.
• Interact with Asianet advertisements, digital campaigns, or marketing content available on third-party platforms or other digital media.
• Make transactions electronically through Asianet's digital platform or services.
• Visit an office, customer service center, or other facility managed by Asianet.
• Establish a cooperative relationship with Asianet, including in due diligence, procurement, contract administration, business correspondence, and registration as a business partner.
• Apply for a job, follow the recruitment process, or participate in internship programs or talent development activities organized by Asianet.
• We lawfully obtain your Personal Data from third parties, affiliates, business partners, service providers, or publicly available sources in accordance with applicable laws and regulations.
• Attend seminars, webinars, trainings, exhibitions, customer gatherings, or other activities organized or supported by Asianet.
• Enter an area equipped with security systems, including Closed-Circuit Television (CCTV), access control systems or visitor registration systems.
• We perform identity verification, validation of customer information, fraud prevention, risk management, or fulfillment of compliance obligations under applicable laws and regulations.
• Participate in customer satisfaction surveys, market research, or service quality improvement programs conducted by Asianet or a party designated by Asianet.
• We receive information generated automatically from the use of services, devices, applications, or networks, including log data, IP addresses, device information, usage data, and other technical information.
• We obtain your Personal Data from referrals, recommendations, or information about other parties to Asianet to the extent permitted under applicable law.

4. PERSONAL DATA WE COLLECT

Personal Data is any data relating to a natural person that has been identified or can be identified, either directly or indirectly, either separately or in combination with other information, through electronic or non-electronic systems, including but not limited to names, addresses, telephone numbers, religion, ethnicity, health data, biometrics, and financial information.

Asianet may collect your Personal Data in any type or type of data that includes but is not limited to:

• Contact information, such as full name, date of birth, address, email address and phone number.
• Identifying information, such as Identity Card (KTP), Family Card (KK), passport, Taxpayer Identification Number (NPWP), BPJS number, Driver's License (SIM), or other government-issued identification.
• Demographic information, such as age range, marital status, gender, nationality, religion, race, and ethnicity.
• Photos and video recordings, including photos or recordings for documentation, contests, agreement implementation reporting, and CCTV.
• Specific information related to products and services.
• Banking information, such as account number, credit card information, and bill payment history.
• Your social media links or public profiles, and personal information that may appear therein, provided during customer support transactions.
• The password of the account you may have created.
• Other personal information that You may provide while using Asianet's products and/or services.
• Employment and business relationship information, such as company name, job title, company email address, work phone number, and other partnership information.
• Account authentication and security information, such as username, PIN, OTP, security questions, authentication tokens, and identity verification data.
• Information on service use and user activities, including access history, application or website activity, usage preferences, and interactions with Our products and services.
• Technical and network information, such as IP addresses, cookies, device identifiers, log data, and other device and connectivity information.
• Communication and correspondence information, including recordings of conversations, emails, messages, complaints, service requests, and other communications with Us.
• Compliance, security, and fraud prevention information necessary for risk management, verification, investigation, and compliance with legal obligations.
• Transaction and commercial activity information, including purchase history, promotions, vouchers, loyalty programs, and other transactions.
• Geographic location information, such as location obtained from IP or GPS addresses, base stations, and signals.
• Biometric information used for identification or authentication, including fingerprints, voice, audio, facial recognition and/or video features.
• Information from and about technologies on which our services are used, including internet of things (IoT), computers, phones, tablets, and connected technologies in homes or vehicles.
• Information obtained from legitimate third parties or publicly available sources in accordance with applicable laws and regulations.

5. HOW WE PROCESS PERSONAL DATA

A. Purposes of Processing

We may use the Personal Data collected for the following purposes as well as other purposes permitted by Applicable Laws and Regulations ("Purposes"):

1) Specifically, if you are a user of the service/product, We may use your Personal Data:

• To identify and register you as a user and to create, verify, deactivate, or manage your account on the platform We provide.
• To facilitate or enable verification necessary before We provide services or register You as a User.
• To enable Us to provide services, whether available, requested, or available in the future.
• To process and facilitate orders and payment transactions made by you, including transactions through payment cards, electronic money, electronic wallets, or accounts available on the Services.
• To notify you of transactions or activities within the Services or systems connected to Our Services.
• To communicate with you and send you data in connection with the use of the Services, including complaints.
• To notify you of updates to the Platform, including security, versions, features or changes to the Services.
• To process, resolve and respond to complaints, problems, questions and suggestions We receive.
• To maintain, develop, test, improve, and personalize the Services to meet your needs and preferences as a User.
• To monitor and analyze the User's activities, behavior, and demographic data.
• To offer or provide services from Our affiliates or partners.
• To send direct or focused marketing communications, advertisements, vouchers, surveys, special offers or promotions.
• To send information about our product and service offerings or those offered by third parties that We think may interest you.

2) Specifically, if You are Our business Partner, including vendors, partners, third parties and so on, We may use Your Personal Data:

• To enable Us to provide services, whether available, requested, or available in the future.
• To identify and register you as a user and create, verify, deactivate or manage your account on the platform or application used between You and Us.
• To facilitate verification before establishing cooperation with Us, including Know Your Vendor (KYV) or Know Your Partner (KYP).
• To communicate with you and send you data in connection with the cooperation between Us and you.
• To process, resolve and respond to complaints, problems, questions and suggestions We receive.
• For operational activities such as network connectivity and diagnosing problems.
• To generate statistical and analytical data for testing, research, analysis, product development, commercial partnerships, and cooperation.
• To facilitate business asset transactions, including mergers, acquisitions, or asset sales involving Us and/or Our affiliates.

3) Specifically, if you are a worker or prospective worker, We may use your Personal Data to:

• Carry out recruitment, selection, assessment, interview, and evaluation of candidates.
• Conduct identity verification under Know Your Employee (KYE), including qualifications, certifications, work experience, and references.
• Prepare and manage work agreements, assignment letters, mutations, promotions, position rotations, and personnel status changes.
• Manage personnel administration, including personnel, family, emergency contact, and employment information.
• Manage payroll, incentives, bonuses, allowances, reimbursement, and other worker benefits.
• Enroll and manage participation in social security, health insurance, life insurance, pension funds, and welfare programs.
• Manage attendance, leave, overtime, official trips, work assignments, and employment administration.
• Organize training, competency development, certification, performance appraisal, career planning, and human resource development.
• Provide work facilities, equipment, employee identity cards, and supporting facilities.
• Manage resignation, retirement, termination, handover, and administration after employment ends.
• Maintain historical personnel data necessary for workers' rights, administrative needs, and company obligations.

4) We may also use your Personal Data more generally for the following purposes:

• To perform related business processes and functions.
• To prevent, detect and investigate suspicious, prohibited, illegal, unauthorised or fraudulent transactions or activities.
• To provide notices in relation to your Personal Data, including in the event of a failure to protect it.
• To comply with obligations under Applicable Laws and Regulations, including requests, investigations, filing, reporting, licensing, audits, due diligence and investigations.
• For other Purposes that We notify You and, if required, obtain your consent for.
• For research and studies related to our business operational activities.
• To conduct accounting, auditing, reconciliation and billing; protect Our legal rights and You; and perform contractual obligations.
• To process decision-making by Us or third-party partners, including business partners and service providers.
• For litigation or fulfillment of legal obligations.

B. Disclosure and sharing of Personal Data to Processors and Sub-processors

We may disclose, provide access or share Your Personal Data with Our affiliates, partners, and/or other parties to provide services and for other purposes permitted by Applicable Laws and Regulations, including:

• Business purposes, including third-party network infrastructure, human resource, marketing, legal, financial and other relevant service providers, as well as corporate actions such as mergers, asset sales, consolidation, restructuring, financing or acquisition.
• Commercial purposes through Our resellers or other parties to provide products and/or services You choose or need.
• To fulfill legal obligations, handle legal proceedings, protect vital interests, carry out public-interest duties, exercise authority under laws and regulations, and fulfill legitimate interests.
• Emergency purposes related to your health or safety.

When We provide Your Personal Data to affiliates, partners, and/or other parties, We implement measures to limit use to legitimate reasons in accordance with this Privacy Notice and apply adequate confidentiality and security measures.

C. Location and Jurisdiction of Personal Data Processing

Your Personal Data will be stored and processed in Indonesia. However, for providing services, business operations, technical support, technological infrastructure, or other legitimate purposes, it may be accessed, stored, processed, or transferred to affiliates, business partners, service providers, vendors, contractors, or third parties as permitted by law.

We will take reasonable steps to ensure that affiliates and third parties who receive or Process Personal Data on Our behalf apply protection, confidentiality, and security standards comparable to those We apply.

D. Cross-Border Transfer of Personal Data

In processing and/or transferring Personal Data across regions and countries, We will implement necessary measures to ensure compliance with applicable legal provisions and adequate Personal Data Protection standards.

We may transfer Your Personal Data across geographical boundaries where protection is at the same level as We provide. Transfers are carried out under standard contracts with data protection clauses or similar data transfer agreements.

E. Automated Decision Making and Profiling

We and our business partners may use Your Personal Data to support automated decision-making that may impact You. This is systematic processing based on data and algorithms with limited or no direct human involvement.

• Establish a marketing strategy.
• Identify preferences and needs to provide relevant recommendations and support fraud prevention.
• Carry out data analysis, market research, and statistical compilation.
• Provide information to third parties where they cannot identify you individually.

Artificial intelligence may lead to automatic Processing of Your Personal Data. We ensure personal information is made anonymous or de-identified at some stage. Where automated decision-making has a significant impact, We will conduct a Data Privacy Impact Assessment or obtain consent as required by law.

F. Personal Data of Children and Individuals with Disabilities

We will only collect and Process Personal Data belonging to individuals under 18 as determined by applicable laws who have obtained consent and supervision from a legal guardian or parent. Age restrictions may also apply to digital content or services under Indonesian policies and regulations.

For a person with a disability, consent may be given directly by the Personal Data owner or, where that is not possible, by their legal guardian.

G. Impact of Incompleteness or Unavailability of Personal Data

We may be obliged to collect and Process Personal Data to fulfill legal obligations or execute agreements. If You do not provide required, complete and accurate Personal Data, We may not be able to process Your request, provide products or services, or exercise rights and obligations under the applicable relationship.

You may consequently experience limitations in accessing features, using services, participating in programs or offers, or receiving relevant information and promotions.

6. HOW WE PROTECT PERSONAL DATA

A. Information Security and Protection Measures

We implement reasonable technical, administrative, and organizational measures in accordance with industry standards to protect Personal Data from unauthorized or unlawful access, use, disclosure, alteration, loss, destruction, or other processing.

Safeguards may include:

• Access control and restrictions based on work needs (need-to-know basis).
• Appropriate security technologies, including encryption when data is stored or transmitted.
• Information security policies, procedures, and standards.
• Periodic monitoring, testing, audit, and evaluation of security measures.
• Continuous improvement of Personal Data Protection practices and information security.

No method of data transmission over the internet, communication networks, or electronic storage systems can be guaranteed completely secure or risk-free. You are responsible for maintaining the confidentiality of account information, passwords, verification codes, OTPs, and other credentials, and for securing the device used to access Our services.

B. Incident Handling and Management

We implement procedures to identify, assess, handle, mitigate, and recover the impact of information security incidents affecting the confidentiality, integrity, or availability of Personal Data.

If We become aware of an incident resulting in a failure to protect Personal Data, We will conduct the necessary assessment and investigation. Where notification criteria under applicable laws are met, We will notify authorities and/or the Personal Data Subject in accordance with applicable regulations.

If You become aware of or suspect unauthorized access, improper use, or a security incident affecting Your Personal Data, contact Us immediately through the channels listed in this Privacy Notice.

7. YOUR RIGHTS AS THE OWNER OF PERSONAL DATA

We strive to maintain the accuracy, completeness, and currency of Personal Data We process. In accordance with applicable laws and regulations, You may:

• Obtain information about the identity, purpose and basis of Processing, types of Personal Data processed, and other required information.
• Request updates, corrections, or deletion of inaccurate, incomplete, or no longer relevant Personal Data.
• Access Personal Data We process and obtain a copy in an available format, including for portability where required.
• Request restriction, delay, cessation or deletion of certain Processing, subject to legal, compliance and retention obligations.
• Withdraw consent from Processing, insofar as it is not related to basic telecommunications services and is permitted by law.

To exercise your rights, you must follow Our policies, procedures, and stages. A request to withdraw services remains subject to Our consent to the fullest extent permitted by law.

For updates or corrections based on Your request, We may provide confirmation or notification when changes are made. You may exercise your rights by contacting the information provided in this Privacy Notice.

8. PROVISIONS ON RETENTION OF PERSONAL DATA

We retain Personal Data as long as necessary to fulfill the purposes described in this Privacy Notice, including providing products and services, fulfilling legal and compliance obligations, resolving disputes, exercising rights and obligations, protecting legitimate interests, and meeting operational and administrative needs.

The retention period considers the nature of the Personal Data, processing purpose, legal requirements, and legitimate business needs. Personal Data may be stored physically or electronically by Us or service providers acting on Our behalf.

Once the purpose has been fulfilled or the retention period expired, Personal Data will be deleted, destroyed, anonymized, or processed so it can no longer be identified as Personal Data, in accordance with applicable law and Our procedures.

In certain circumstances, authorized third parties, including government agencies and regulators, may retain Personal Data lawfully received under applicable laws or legal relationships.

9. ADDITIONAL INFORMATION

A. Use of Cookies

When You access Our website, We may use essential cookies to support operation, security, and basic performance. Their purposes are to:

• Guarantee a safe and efficient user experience.
• Facilitate smooth navigation throughout the site.
• Maintain user sessions and access to certain features.

If you use our website, you agree to the use of these essential cookies.

B. Responsibility for Third-Party Websites and Services

Apps and marketing materials may contain links to third-party websites. Personal Data Processing on those websites is controlled by and is the responsibility of the relevant third party. Their terms and privacy policies/notices apply, so We recommend reading them before access.

Ads on Our Apps or Marketing Materials link to advertisers' websites. Data collected from clicks is collected and used by the relevant advertiser under its privacy policy/notice.

C. Marketing Communication and Promotional Materials

We and Our partners may send direct marketing, advertising and promotional communications via app push notifications, in-app messages, posts, chat platforms, social media, and email if You have subscribed or agreed to receive Marketing Materials. You may opt out at any time using the unsubscribe option or another method provided by Us.

If you opt out, We may still send non-promotional messages such as receipts or account information.

D. Our Responsibilities

You agree that the Company is not responsible for costs, losses, fines, liabilities, or penalties experienced by you or third parties as a result of your breach of the terms, representations, warranties, or obligations in this Notice.

You agree to indemnify and hold the Company harmless from actions, claims, demands, costs, losses, fines, liabilities, penalties, and legal fees resulting from such breach, including providing incorrect, incomplete, or inaccurate Personal Data, failure to update Personal Data, or failure to obtain required consent or authorization from third parties.

The Company's liability, if any, is limited to the fullest extent permitted by applicable law. The Company will not be liable for consequential, incidental, indirect, punitive, or loss of profits, data, business, or reputation.

E. Dispute Resolution

If You have questions, inputs, or objections regarding Our Processing of Personal Data, contact Us first through the available communication channels so We can review and follow up appropriately. Without prejudice to your legal rights, You may pursue other available mechanisms under applicable law.

F. Changes and Updates to the Privacy Notice

We reserve the right to change, update or supplement this Privacy Notice in accordance with business needs, technological developments, changes in Processing practices, and legal or regulatory requirements.

Changes will be published through Our official channels and take effect from the stated effective date. We encourage periodic review. Continuing to access or use Our products or services after publication acknowledges receipt of information regarding the update.

The most current version takes effect from the date stated in the document and supersedes the previous version unless otherwise specified.

10. CONTACT US

For questions, comments, inquiries or claims regarding this Privacy Notice, contact us by email: compliance@asianet.co.id

11. DOCUMENT HISTORY