This Privacy Policy outlines how PT Una Darma Indonesia, its subsidiaries and affiliated companies (collectively referred to as "Una", "we", "us", or "our") collect, use, process, disclose, transfer, and retain your personal data through the Una Platform. The Una Platform refers to Una's websites and any subdomains (collectively referred to as the “Website”), web-based applications, tablet applications, mobile applications, and other smart device applications, along with any associated application programming interfaces (collectively referred to as the “Application”), and all related services (collectively referred to as the “Service”).

This Privacy Policy applies to users, agents, partners, suppliers, contractors, and service providers (collectively referred to as “you”, “your”, or “yours”).

Personal data refers to information about an individual that can identify the individual, whether on its own or when combined with other data, either directly or indirectly, through electronic or non-electronic means (“Personal Data”).

We are committed to protecting the privacy, confidentiality, accuracy, and security of the personal data you provide. We typically collect, use, process, disclose, transfer, and retain your Personal Data in accordance with this Privacy Policy with your consent, or in compliance with applicable laws, such as where:

• it is required for us to enter into or perform a transaction and/or a contract with/for you;

• for our legitimate interests or the legitimate interests of any other party, including but not limited to for the purposes set forth in this Privacy Policy; and/or

• it is required for us to comply with legal requirements.

You must be 18 years or older to be eligible to use the Una Platform. Those under the age of 18 must be represented by a parent or legal guardian, and the use of the Una Platform is the full responsibility of the parent or legal guardian.

Please read this Privacy Policy carefully to ensure you understand them. If you do not agree to this Privacy Policy, you must not access or use the Una Platform or any of its related Service.

1. Personal Data

The types of Personal Data and other data we collect vary depending on how our Website, Application and Service are used, the method of collection, and the specific service or transaction requested. These may include:

Personal Data

The data we collect includes but is not limited to:

• personal information, such as name, gender, date of birth, marital status, employment status, nationality, residency status, driving licence, National Identity Card (KTP), passport, or other personal identification documents;

• contact information, such as phone number, mailing address, and email address; 

• biometric data, such as profile photo;

• medical and health information, such as health status, medical reports, injury or disability information, medical procedures performed, personal habits (e.g. smoking or alcohol consumption), and medical history;

• payment information, such as bank account information, credit card information, debit card information, billing and payment records, and transaction history; 

• insurance information, such as claims history, instances of suspected fraud, and usage history; and 

• other data as required by the laws and regulations of the Republic of Indonesia.

Other Types of Data

The other data we collect includes but is not limited to:

• device and technical information you provide when using our Website and Application, such as your Internet Protocol (IP) address, Media Access Control (MAC) address or other unique identifiers, cookies, operating system, platform, and geolocation;

• usage data related to how you navigate and interact with our Website and Application, including pages visited, actions taken, and the duration of time spent on each section; and 

• communication preferences, participation in loyalty programmes, purchase history, browsing history, referral sources, campaign data, and customer feedback data. 

2. Collection of Personal Data

Personal Data may be collected directly from you or indirectly through various ways, including when:

• you create an account and use the Una Platform;

• you submit any form, including but not limited to an application, declaration, consent, or claim;

• you enter into any agreement or provide documentation or information in respect of your interactions and transactions with us, including the use of our Service;

• you join our loyalty programmes, participate in promotions or events, such as competitions or roadshows organised by us or our partners, or subscribe to our mailing list or other communication channels;

• you use the services of any insurers, financial institution, broker, or intermediary, such as agents, distributors, or other business partners we work with, to obtain quotes, products, or services;

• you apply for any insurance we offer or distribute, whether for yourself or another party;

• a policyholder names you as the insured person or the beneficiary;

• you apply for any loan, whether for yourself or another party;

• you register as a fundraiser or a donation recipient for fundraising within the Giving service available on the Una Platform;

• as a fundraiser, you provide information about the fundraising, including but not limited to information on the use of donations, images, photos, and videos, for the purpose of describing the fundraising within the Giving service; 

• as a donation recipient, you submit your Personal Data, including but not limited to images, photos, and videos, to describe your status and experiences related to the fundraising within the Giving service;

• you interact with our staff, including customer service officers, marketing personnel, agents, or other representatives, such as through phone calls, in-person meetings, digital platforms (including social media), workshops, or emails;

• your images are captured through closed circuit television (“CCTV”) cameras while you are within our premises, or through photographs or videos taken by us or our representatives during events we host or organise;

• you submit an employment application or provide documents, such as your resume or curriculum vitae, while seeking employment with us;

• we receive referrals or information from your authorised representatives, business partners, or third parties;

• we seek or receive information about your insurance applications or claims, including but not limited to information from other insurers, healthcare providers, motor workshops, your authorised representatives, or relevant authorities;

• we obtain Personal Data from publicly available or governmental sources;

• we collect any Personal Data mandated by legal or regulatory authorities to meet legal obligations, aid law enforcement, and support investigations or audits; and

• we collect Personal Data through automated means, such as cookies, web beacons, or other similar technologies, and when you interact with the Una Platform.

3. Personal Data of Third Parties and Minors

There may be instances where you provide us with Personal Data about a third party, such as your spouse, children, parents, employees, or wards. This may occur when you name them as an emergency contact, insured person, or beneficiary, or when purchasing products like group insurance. Additionally, if you are a fundraiser or donation recipient, you may provide us with Personal Data related to other individuals involved in your fundraising. By submitting their Personal Data, including that of minors or wards under your care, you confirm that you have obtained their consent, or in the case of minors and wards, that you are legally authorised to provide consent on their behalf, for us to collect, use, and share their information as outlined in this Privacy Policy.

4. Purpose of Collection and Use of Personal Data

Generally, we collect, use, disclose, transfer, or retain your Personal Data to:

• assess and process any applications or requests you make for the Service we offer;

• verify your identity and the accuracy of the information you provide;

• facilitate the process of obtaining insurance and/or loan from third-party product providers and make them available for your access;

• facilitate the pricing, underwriting, issuance, and servicing of insurance policies, including payments, renewals, claims processing, and termination, by sharing your Personal Data with third-party insurers;

• facilitate the process of the issuance and servicing of loan contracts, by sharing your Personal Data with third-party lenders;

• provide you with updates and administrative notifications related to the products and services you use, such as insurance premium payment or loan repayment due dates;

• facilitate any claims and payments under your insurance policy, including requesting information such as medical reports and test results from healthcare providers, by sharing your Personal Data with third-party insurers;

• process your donation to any fundraising through the Una Platform;

• verify bank accounts and facilitate the disbursement of donations to fundraisers or donation recipients; 

• fulfil any promised rewards to donors in the event that a reward has been offered in any fundraising and/or marketing activity;

• manage administrative and business operations, and comply with internal policies and procedures;

• utilise automated decision-making or profiling where necessary;

• conduct internal operations, such as record-keeping, data analysis, testing, research, and statistical analysis to ensure accuracy, compliance, and efficiency; 

• store, host, and back up Personal Data, including via cloud services;

• monitor, detect, and prevent fraud, security incidents, and other unlawful activities; 

• manage the safety and security of our premises and services, including conducting CCTV surveillance;

• conduct audits, compliance checks, and risk assessments to ensure adherence to legal and regulatory obligations;

• facilitate business transactions, such as mergers, acquisitions, or the sale of assets, where Personal Data may be transferred as part of the transaction;

• conduct market research, surveys, and customer analysis to gain insights into customer needs and preferences, thereby improving our products and services;

• manage customer relationships, including handling inquiries, complaints, feedback, and requests;

• communicate with you about our products and services, including promotional offers, loyalty rewards, marketing, and advertising;

• manage subscriptions to our newsletters;

• offer other financial products and complementary services from business partners or affiliates;

• process and manage your requests for referral services;

• organise and manage events, competitions, and lucky draws;

• manage and prepare reports on incidents and accidents;

• provide training and quality assurance for our staff and agents to enhance service delivery;

• notify you of important corporate updates and announcements, or changes to our Privacy Policy; and

• carry out any other matter related to or reasonably necessary for any of the aforementioned purposes.

5. Disclosure of Personal Data

We take reasonable steps to protect your Personal Data against unauthorised disclosure. However, your Personal Data may be shared with various parties for the purposes mentioned above, as well as for other purposes permitted by applicable laws and regulations, both domestically and internationally. These parties include but is not limited to:

• your financial adviser, agent, or insurance broker;

• your employer or group policyholder;

• third-party referrers;

• family, relatives, appointed executors, and the professional advisers in relation to your will(s) or estate administration;

• our business partners and affiliates;

• companies providing services related to insurance, reinsurance, loan, and other products and services offered by us;

• surveyors, loss adjusters, investigators, motor workshops, healthcare providers, and other service providers involved in the insurance claim validation and assessment processes;

• individuals, groups, non-profit organisations, business entities, or legal entities that conduct fundraising through the Una Platform;

• agents, contractors, or service providers that assist us with services, such as printing, courier services, mail distribution, data storage, cloud services, training, data analytics, promotions, marketing, and research;

• payment processors and facilitators;

• our professional advisers, such as auditors and lawyers;

• relevant government regulators, authorities, or law enforcement agencies;

• any business partner, investor, assignee, or transferee involved in business asset transactions, including merger or acquisition. In such cases, we will notify you if your Personal Data is transferred as part of the transaction; and

• any other party you authorised us to disclose your Personal Data to.

6. Protection of Personal Data

We will make reasonable efforts to protect and maintain the confidentiality of your Personal Data by implementing appropriate security measures to prevent unauthorised use, access, disclosure, or other risks. However, please be aware that no method of transmitting information over the internet is entirely secure and no method of storing data, both physically and digitally, is entirely secure. While we strive to protect your Personal Data, we cannot guarantee its absolute security during transmission via any online means; any transmission is at your own risk. We strongly recommend that you take additional precautions to safeguard your Personal Data when using the internet.

7. Accuracy of Personal Data

We will make reasonable efforts to verify the accuracy and completeness of your Personal Data at the time of data collection. However, we rely on your participation to keep your Personal Data up to date. If you believe any Personal Data we hold is inaccurate, incomplete, or outdated, you have the right to request a correction or update of the data. Please contact us using the information in Section 14 (Contact Information) to make any necessary changes.

8. Your Rights to Data Access and Correction

In accordance with applicable laws and regulations, you have the right to:

• inquire about and request access to your Personal Data, including obtaining a copy of the data we hold about you. In certain cases, a reasonable fee may be charged for this service, as permitted by law;

• correct any inaccuracies or update your Personal Data to ensure it is accurate, complete, and up to date; and

• obtain information about how your Personal Data is being processed, including the purposes of processing the data.

However, please note that we may be required to refuse access to or changes to your Personal Data if doing so would:

• endanger the security, physical health, or mental health of yourself or others;

• impact the disclosure of Personal Data belonging to other individuals;

• be contrary to the interests of national defence and security; or

• be necessary to comply with legal, regulatory, or operational requirements.

To exercise any of these rights, please contact us using the information in Section 14 (Contact Information). We will respond to your request in accordance with applicable laws and within the prescribed timeframes.

9. Withdrawal of Your Consent

To the extent permitted by applicable laws, you have the option to withdraw your consent, limit or end the processing of your Personal Data, and withhold your Personal Data when requested. However, doing so may prevent us from providing the products and/or Services you have requested or currently receive from us. This may also affect our ability to perform other processing activities described in Section 4 (Purpose of Collection and Use of Personal Data) and could affect your access to certain features of the Una Platform. 

If you wish to exercise your rights as described above, please contact us using the information in Section 14 (Contact Information). We will process your request in accordance with applicable laws and within the prescribed timeframes.

10. Retention and Deletion of Personal Data

We will retain your Personal Data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, or as required or permitted by applicable laws and regulations. 

Once your Personal Data is no longer needed for these purposes, or if you request its deletion, we will take appropriate and reasonable steps to delete, destroy, or anonymise your data. 

In certain circumstances, we may be required to retain your Personal Data for a longer period, such as to comply with legal obligations, resolve disputes, enforce our agreements, or protect our legitimate interests. During this period, your Personal Data will be securely stored and isolated from further processing until it can be deleted.

If you wish to request the deletion of your Personal Data, please contact us using the information in Section 14 (Contact Information). We will process your request in accordance with applicable laws and within the prescribed timeframes.

11. Links to Other Websites

Our Website and Application may contain links to other websites operated by third parties. Please note that we are not responsible for the privacy practices of these third parties, and we recommend that you study and review their privacy policies carefully.

12. Updates to This Privacy Policy

We reserve the right to update or amend this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any updates will be posted on our Website and Application, with the "Last Updated" date revised accordingly, and we will make reasonable efforts to provide notice of the updates to the Privacy Policy on our Website and Application.  

We encourage you to check back frequently to review any updates or changes to this Privacy Policy. 

By continuing to use the Una Platform after any updates or changes to the Privacy Policy, you are considered to have agreed to be bound by the updated terms, even if you have not reviewed them.

13. Languages

This Privacy Policy is written in both Indonesian and English. In the event of any inconsistency or difference between the Indonesian and the English versions, the Indonesian version shall prevail. The English version shall be amended and interpreted to remain consistent with the Indonesian version.

14. Contact Information

If you require further information regarding this Privacy Policy or the handling of your Personal Data, please contact us at:

Email: [email protected]

Phone: +62 21 21191212

Address: Jl. Gelong Baru No. 6, Jakarta Barat, DKI Jakarta 11440, Indonesia