Introduction

This Personal Data Protection Policy ("Policy") provides information about how PT Kay Hian Sekuritas (KH) processes and protects your personal data.

1. Legal Basis

The legal basis for the preparation of this Policy is Law Number 27 of 2022 concerning Personal Data Protection ("PDP Law") as well as implementing regulations, amendments, and/or substitutes for such regulations that will exist and apply in connection with the Protection of Personal Data.

2. Processing of Personal Data

The Processing of Personal Data includes:

a. Collection of Personal Data

KH processes your Personal Data as required through a variety of sources, but not limited to:

1. Information you provide in the Account Opening Form, when using KH service products (including but not limited to Online Trading Services created with KH).
2. Through your verbal and written communications with us and/or our Marketing Personnel.
3. From any Information or files that you submit or upload or that you collect when you use our Online Trading Services.
4. From the participation of activities held by KH through webinars, seminars or other activities.

The data collected includes, but is not limited to:

1. General Data

   Full name, Population Identity Number (for Indonesian Citizens), Passport number (for foreign citizens), address, gender, nationality, place and date of birth, marital status, biological mother's maiden name, email address, phone number, educational background, emergency contact name;

2. Specific Data

   Employment and financial data, tax data, bank account data, selfies and/or wefie, voice recordings, signatures, biometric data, sources of funds, investment objectives, beneficiaries and Information; or

Any data you provide to KH when you apply for or use KH products and services or when you interact with KH.

b. Use of Personal Data

KH uses your personal data to:

1. Providing and improving services, including:
   1. Processing your enquiries and requests for the opening of Accounts, services and products with KH;
   2. Provide services and products to you of KH and KH affiliates, marketing partners and related companies;
   3. Administer and manage your Account;
   4. Processing Transaction instructions;
   5. Verification of Information related to Transactions, send correspondence, reports, confirmations, complaints or notices to you that may involve the disclosure of certain personal data about you;
   6. Conduct market research and make analysis reports for the purpose of developing and providing KH services.
2. The fulfillment of legal obligations includes, but is not limited to: 
   1. Implementing the Know Your Client (KYC) principle and implementing the principles of Client Due Diligence (CDD) and Enhanced Due Diligence (EDD) for the implementation of anti-money laundering programs, terrorism financing prevention and prevention of the proliferation of weapons of mass destruction (AML, PPT and PPPSPM);
   2. Verify the correctness of your Information regarding the use of the service;
   3. Submit reports in accordance with the provisions of applicable regulations and laws and regulations to the OJK, Stock Exchange, KSEI, KPEI and other authorities;
   4. Implement and comply with all laws and regulations and regulations.

c. Disclosure of Personal Data

KH will share your Personal Data with other Third Parties only in the manner set out in this policy or set out at the time the Personal Data is collected, including to the following parties:

1. Custodian banks and/or other securities companies in the context of validating securities for the Second Party Securities Transaction Instructions;
2. The Indonesia Stock Exchange, KPEI, KSEI, OJK and other government agencies that according to applicable laws and regulations are authorized to request such information;
3. Police, Prosecutors, Judges, and/or other Law Enforcement if it is based on an investigation order or court order or is treated based on the law or ongoing legal process;
4. The parent company or affiliated party of the First Party at home or abroad in order to fulfill the obligations of the applicable laws and regulations, both at home and abroad. In this case, you are deemed to be aware and agree that KH may require additional documents and/or forms that need to be signed if the Second Party is a Party regulated by laws and regulations;
5. Other parties in the event of a case, lawsuit or other legal process where disclosure of information is required according to KH to protect their interests.

3. Data Subject Rights

KH grants you the right as a personal data subject to:

1. Obtain Information about the purposes for which personal data is collected;
2. Complete, update or correct incorrect personal data;
3. Obtain a copy of personal data;
4. Terminate the processing, deletion or destruction of personal data;
5. Revoke consent to the processing of personal data;
6. Object to automated processing that has a significant impact;
7. Suspend or restrict the processing of personal data;
8. Suing and receiving compensation for a breach of the processing of Personal Data.

This excludes for:

1. Defense and national security interests;
2. The importance of the law enforcement process;
3. Public interest in the context of state administration;
4. The importance of supervision of the financial services sector, monetary, payment system and financial system stability carried out in the context of state administration; or
5. Statistical and scientific research interests.

4. Transfer of Personal Data

In the event that KH needs to transfer your personal data outside the territory of Indonesia, KH will ensure that the destination country has a level of personal data protection equal to or higher than the applicable personal data protection in Indonesia.

If the destination country does not have an equivalent or higher level of personal data protection, KH will ensure that there is adequate and binding personal data protection.

If there is no adequate and binding protection of personal data, KH may still transfer your personal data as long as it complies with the applicable laws and regulations, including but not limited to obtaining your consent.

5. Storage of Personal Data

KH will retain personal data for the required period of time with reference to the applicable laws and regulations or in accordance with the retention or retention period.

6. Data Security

KH is committed to keeping your personal data secure by using appropriate safeguarding measures. KH urges you to always maintain the confidentiality of your passwords and other personal information. KH never asks for your password through any communication channel.

7. Children's Personal Data

Children's Personal Data is managed specifically by requesting the consent of the child's parents and/or guardian.

8. Policy Changes

KH may update this Personal Data Protection Policy from time to time. KH will notify you of any changes related to this policy by uploading the latest Version on KH's official website. KH recommends reviewing and reviewing this Personal Data Protection Policy periodically for any changes.

If you have any questions about this Personal Data Protection Policy, please contact us at:

PT Kay Hian Sekuritas
UOB Plaza Thamrin Nine Lt. 36
Jl. MH Thamrin Kav 8-10
Jakarta 10230

Phone: 021-29933888
Email: csindonesia@kh.co.id
Operation Hour: Monday to Friday, 09.00-17.00 WIB