Privacy Policy

We, PT MSIG Sharia Life Insurance Indonesia ("we", or"MSIG Life Syariah"), a company licensed and supervised by Indonesian Financial Services Authority, respect the privacy of every individual who visits our online platforms ("Online Platforms"). By accessing or using our Online Platforms, please read this Privacy Policy carefully to understand how we collect, use, process, store, update, correct, transfer, disclose, disseminate, publish, and/or destroy your Personal Data in accordance with provisions of Indonesian Personal Data Protection Law ("PDP Law"). The term Personal Data as used in this Privacy Policy shall have the meaning set out in the PDP Law. By submitting your Personal Data to us, you are deemed to have provided your consent, where required and as applicable, to the collection, use, processing, disclosure, and other processing of your Personal Data as described in this Privacy Policy.

What Does This Privacy Policy Cover?

This Privacy Policy is intended to inform you about how MSIG Life Syariah collects, uses, stores, discloses, and protects your Personal Data that is collected during your visit to any of our Online Platforms.

Who Is Responsible for the Personal Data Collected Through These Online Platforms?

Your Personal Data is controlled and protected by MSIG Life Syariah, a company duly incorporated under laws of Republic of Indonesia. Special Notice – If You Are Under 18 Years of Age - Our Online Platforms are not intended for individuals under age of 18. We do not knowingly collect, use, disclose, or otherwise process, in any form, the Personal Data of individuals under 18 years of age. If you are under age of 18 and wish to make an inquiry or use our Online Platforms in a manner that requires you to submit your Personal Data, please ask your parent or legal guardian to do so on your behalf.

Whether you are a prospective customer or customer, business partner, job applicant, prospective agent or agent, employee, or any other Personal Data Subject whose Personal Data is processed by MSIG Life Syariah, protecting your Personal Data is our commitment and forms part of our compliance with the applicable personal data protection laws and regulations of the Republic of Indonesia, particularly the Indonesian Personal Data Protection Law (PDP Law), as amended or supplemented from time to time.

Purpose of Collecting and Processing Your Personal Data

We may collect and process your Personal Data as a Personal Data Subject. In general, your Personal Data is processed ("Processing Purposes") for the following purposes:

1. To provide insurance products and services, including underwriting and insurance coverage or protection to you as a prospective customer or customer of MSIG Life Syariah; and
2. To support our other business and operational activities.

Processing Purposes include, but are not limited to, following:

1. Insurance Underwriting, Policy Administration, and Provision of Insurance Services

• Processing insurance applications.
• Issuing and delivering insurance policies by email or post.
• Conducting insurance risk assessments.
• Carrying out MSIG Life Syariah's operational activities.
• Receiving and handling insurance claims, including processing medical history, communicating with hospitals and healthcare providers, and conducting claim verification and investigations.
• Processing and paying insurance benefits and claims.
• Managing co-insurance arrangements, including claims arising from co-insurance.
• Providing customer services, including handling inquiries, complaints, and disputes.
• Processing commission payments.
• Cooperating with relevant parties in relation to insurance applications and/or claims, whether submitted to MSIG Life Syariah or other insurance companies.
• Cooperating with relevant parties to detect, prevent, and investigate fraud and financial crimes.
• Managing legal proceedings involving MSIG Life Syariah and/or its sales representatives.
• Managing reinsurance and/or retrocession arrangements.
• Carrying out other activities related to the provision of insurance services.

2. Employee Recruitment

• Conducting background checks on prospective employees and employees.
• Conducting medical examinations for prospective employees and employees.
• Managing documentation and administrative processes relating to employee recruitment and employment.
• Processing employee termination.

3. Online Media/Device Visitors

• Providing, maintaining, and improving the operation and functionality of MSIG Life Syariah's Online Platforms.
• Offering information about other insurance products and services that may enhance the protection available to prospective customers and customers.

4. Marketing

• Contacting you regarding administrative matters and our products and services.
• Conducting market research, business analysis, customer profiling, and statistical analysis.
• Providing general information about our products and services, including announcements, promotional campaigns, and product discounts.
• Conducting marketing and promotional activities, including prize draws, promotional programs, and providing information that may be of interest to you, with the aim of improving our products and services.

5. Agent Recruitment

• Conducting background checks on prospective agents and agents.
• Managing documentation and administrative processes relating to agent recruitment and agency administration, including commission payments, promotions, demotions, and other agency-related processes in accordance with MSIG Life Syariah's policies.
• Processing agent termination.

6. Compliance with Legal Obligations and Legitimate Interests

• Complying with court orders, applicable laws, and regulatory requirements.
• Conducting due diligence, including compliance with Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), Counter-Proliferation Financing (CPF) requirements, and other applicable legal and regulatory obligations.
• Responding to court orders, legal proceedings, requests from regulators or competent authorities, protecting against fraud and other unlawful activities, supporting risk management activities, exercising legal rights available to MSIG Life Syariah, minimizing potential losses, and complying with applicable legal and regulatory requirements, including but not limited to the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) for international exchange of information.

As a Personal Data Subject, you are also required to provide the information and documents necessary to satisfy such legal and regulatory requirements ("Relevant Information") and promptly notify MSIG Life Syariah of any changes to such Relevant Information.

7. Other Business Activities

• Enhancing our systems infrastructure and business operations to provide better services in connection with your insurance policy.
• Conducting and supporting our business operations, including disaster recovery and data storage.
• Facilitating potential acquisitions, demergers, mergers, and other corporate transactions, where applicable.
• Receiving, managing, and responding to inquiries, requests, registrations, and complaints.
• Exercising the rights and fulfilling the obligations of MSIG Life Syariah, its affiliates, and/or its controlling company in connection with our products and services, including audits, compliance activities, and investigations.
• Protecting the rights, assets, and property of MSIG Life Syariah.
• Complying with all applicable laws and regulations of the Republic of Indonesia and other legal obligations.

LEGAL BASIS FOR PERSONAL DATA PROCESSING

MSIG Life requires your Personal Data for each of the previously stated processing purposes. We will use the most relevant legal basis for such purposes in accordance with the PDP Law. The legal bases for MSIG Life to process your Personal Data may consist of one or more of the following:

1. Performance of a Contract

   We process your Personal Data where it is necessary to enter into, perform, or administer a contract with you. This includes processing your request to enter into an agreement with MSIG Life Syariah, issuing insurance policies, and fulfilling our contractual obligations. Examples: Issuing an insurance policy under the contract between you and MSIG Life Syariah, Processing and paying insurance claims, Executing agency agreements or employment agreements.

2. Legitimate Interests

   As a financial services company, MSIG Life Syariah has legitimate business interests in processing the Personal Data we collect. This enables us to provide our products and services effectively and to operate our business efficiently. Examples: Conducting data analysis and customer profiling to provide you with a more personalized experience when using MSIG Life Syariah's products and services.

3. Compliance with Legal Obligations

   There are circumstances in which MSIG Life Syariah is required to process your Personal Data to comply with applicable laws and regulatory requirements. Examples: Disclosing Personal Data to competent authorities, such as the Indonesian Financial Services Authority (OJK), courts, law enforcement agencies, and tax authorities.

4. Protection of Vital Interests

   We may process your Personal Data where necessary to protect your vital interests or those of another individual. Examples: Collecting and processing medical information or medical records in emergency situations where you are unable to provide your consent.

5. Consent

   We may also collect and process your Personal Data based on your consent, where consent is required under applicable law. Examples: Asking whether you wish to receive marketing communications. If you provide your consent, we may contact you with updates, promotional offers, and information regarding MSIG Life Syariah's products and services. For the avoidance of doubt, consent is not relied upon as the legal basis for processing Personal Data for the purposes of Insurance Underwriting, Policy Administration, and the Provision of Insurance Services described above.

PERSONAL DATA WE COLLECT

To achieve Processing Purposes described above, MSIG Life Syariah collects Personal Data from Personal Data Subjects, either directly or through third parties, in compliance with applicable laws and regulations, including the Indonesian Personal Data Protection Law (PDP Law). We collect Personal Data only to extent that it is relevant, adequate, and necessary to provide our insurance products and services effectively and efficiently. Your Personal Data may be obtained directly from you, from third parties that cooperate with MSIG Life Syariah, or from other lawful sources in accordance with applicable laws and regulations. The categories of Personal Data we process may vary depending on purpose and nature of processing. In general, we may collect and process following Personal Data:

• Your name, telephone number, email address, residential address, and correspondence address.
• Identification or passport number and date of birth.
• Occupation, gender, marital status, educational background, and income level.
• Special categories of Personal Data, including information relating to your health and medical history, where relevant to the services provided.
• Financial, banking, and payment information, including credit or debit card details when you purchase products through our Online Platforms.
• Opinions and feedback that you voluntarily provide to us, such as through surveys or customer feedback.
• Browsing history, usage patterns, and other information collected through cookies on our Online Platforms, including pages visited, location, device type, and frequency of visits.
• Your Internet Protocol (IP) address and related technical information.
• Records of your interactions with us, including communications with our customer service team and information obtained when you contact us online or through our applications.
• Information regarding the products and services you currently hold or are interested in, including your preferred payment methods.
• Information regarding your use of our products and services, including claims information and claim payment status.
• Marketing analytics, including records of communications and customer interactions.
• Information obtained from third parties, including insurance risk information, pricing data, claims history, and suspected fraud.
• Information obtained from credit reference agencies and fraud prevention agencies, including credit history and financial circumstances.
• Information relating to suspected fraud or theft, including debt-related information.
• Criminal records or information relating to alleged criminal offences, where permitted by applicable law.
• Financial information, including salary, savings, and expenditure details.
• Employment-related information, where relevant.
• Information purchased or licensed from third parties, including demographic information and marketing lists.
• Insights derived from customer analytics and profiling.
• Information relating to transactions carried out by third parties where another individual uses services associated with your account.
• Any other Personal Data necessary to provide the products or services you have requested.
• Any other Personal Data that we are permitted or required to collect under applicable local or foreign laws.
• We collect only the Personal Data that is necessary to fulfil the Processing Purposes and to provide our products and services to you.

TRANSFER OF PERSONAL DATA

Your Personal Data may be transferred to our affiliates, controlling company, and/or third parties, regardless of their location, where such transfer or storage is necessary to fulfil purposes for which your Personal Data was collected and processed. We will ensure compliance with applicable personal data protection laws and will use our best efforts to ensure that our affiliates and third-party service providers located in other jurisdictions provide a level of protection for your Personal Data that is equivalent to the standards set out in this Privacy Policy and the Indonesian Personal Data Protection Law (PDP Law).

If you reside outside Indonesia, your Personal Data may be processed in the country where you are visiting or residing. We will ensure that any processing and/or transfer of your Personal Data is carried out in accordance with the applicable data protection laws of the country in which the Personal Data is collected or processed, or at a standard that is at least equivalent to the level of protection required under Indonesian law.

For specific Processing Purposes, MSIG Life Syariah may disclose and/or transfer your Personal Data to parties that are relevant and necessary, including:

• Medical professionals, independent experts, and other third parties, including healthcare providers involved in your treatment or care.
• Companies, including service providers, insurance companies, and reinsurance companies, as well as business partners, individuals, or other third parties that cooperate with MSIG Life Syariah.
• MSIG Life Syariah's parent company (PT MSIG Life Insurance Indonesia Tbk.), affiliates, subsidiaries, agents, representatives, and joint venture partners.
• Government authorities, insurance associations, regulatory authorities, and other competent public bodies.

To protect your Personal Data during any transfer, we implement appropriate security measures, including:

• The use of encryption to protect data during transmission.
• Strict information security policies and procedures.
• Additional technical and organizational security measures, where appropriate.

You have read, understood, and agreed to the transfer of your personal data both within and outside your country as outlined in this privacy policy.

DISCLOSURE OF PERSONAL DATA

We may disclose your Personal Data where required to fulfill the purposes described in this Privacy Policy or to comply with applicable laws and regulations. Such disclosure may be made to authorized third parties, including our business partners acting as agents in marketing our products and services, financial and healthcare business partners, third-party service providers that support our business operations, other companies or organizations that assist us in improving our services or carrying out our business activities, and government authorities or regulatory bodies where disclosure is required by law.

We do not sell or rent your Personal Data.

We may disclose and share your Personal Data with the following parties for the Processing Purposes or other legitimate purposes:

• Employees, contractors, and agents of MSIG Life Syariah who require access to your Personal Data solely for purpose of performing their duties in connection with products or services we provide.
• Service providers, agents, contractors, delegates, suppliers, and other third parties (including subcontractors) engaged by us to provide services on our behalf.
• Business partners, including reinsurance companies, insurance brokers, banking partners, affiliates, and other third-party service providers, where disclosure is reasonably necessary and made on a need-to-know basis.
• Our professional advisers, consultants, auditors, legal counsel, and other professional advisers acting in good faith.
• Any person or entity that may succeed to or assume all or part of our rights or obligations under this Privacy Policy.
• Any entity involved in a proposed or actual merger, acquisition, business transfer, restructuring, or other corporate transaction involving MSIG Life Syariah.
• In connection with motor vehicle accident claims, other parties where the exchange of information is necessary, including your name, address, or the details of the driver involved.
• Government authorities, regulators, law enforcement agencies, courts, or other competent authorities where required or permitted by applicable law.
• Any other parties that assist us in carrying out Processing Purposes described in this Privacy Policy.

Except where disclosure is required by law or pursuant to a court order, we will not disclose, share, lease, sell, or otherwise transfer your Personal Data to any third party without your consent or prior notice, where required by applicable law. Where we disclose your Personal Data to a third party, we will take reasonable steps to ensure that such third party protects your Personal Data in accordance with this Privacy Policy and applicable data protection laws. Such third parties are not permitted to use or process your Personal Data for any purpose other than those authorized by MSIG Life Syariah.

If a Personal Data breach occurs that affects the confidentiality, integrity, or availability of your Personal Data and results in unauthorized access, disclosure, loss, destruction, or alteration, we will provide written notification to you within 72 hours (3 × 24 hours) of becoming aware of the breach, or within any other period prescribed by applicable law.

Such notification will include, where applicable:

• Personal Data affected by breach.
• Date, time, and circumstances of breach.
• Measures taken or to be taken by Personal Data Controller to mitigate, investigate, and remediate breach.

STORAGE AND RETENTION OF PERSONAL DATA

• MSIG Life Syariah retains your Personal Data only for as long as necessary to fulfill Processing Purposes described in this Privacy Policy.
• Your Personal Data will be retained in accordance with retention periods prescribed under applicable laws and regulations and our internal record retention policies.
• Once applicable retention period has expired, or where your Personal Data is no longer required for relevant Processing Purposes, MSIG Life Syariah will securely delete, anonymize, and/or destroy your Personal Data in accordance with applicable laws and regulations.

RIGHTS TO ACCESS PERSONAL DATA

Pursuant to the Indonesian Personal Data Protection Law (PDP Law), as a Personal Data Subject, you have the following rights:

• To obtain information regarding identity of Personal Data Controller, legal basis for processing, purposes of collection and use of your Personal Data, and our accountability for such processing.
• To complete, update, and/or correct any inaccurate or incomplete Personal Data.
• To access and obtain a copy of your Personal Data (subject to applicable fees, where permitted by law).
• To request termination of processing and deletion and/or destruction of your Personal Data.
• To withdraw your consent to processing of your Personal Data, where processing is based on your consent.
• To object to decisions based solely on automated processing, including profiling, where such decisions produce legal effects or similarly significant consequences for you.
• To request postponement of, or restriction on, processing of your Personal Data.
• To lodge a claim and seek compensation for any violation of your rights relating to processing of your Personal Data, in accordance with applicable laws and regulations.
• To obtain and/or reuse your Personal Data that has been processed by us in a structured, commonly used, and machine-readable format, where applicable.

These rights may be exercised only to the extent provided under the PDP Law and applicable regulations. Requests may be submitted in writing, either electronically or in hard copy, through our Contact Centre as set out below.

COLLECTION OF NON-PERSONAL INFORMATION

We may automatically collect certain non-personal information about you, such as the type of internet browser you use or the website or online platform that referred you to our Online Platforms. We may also collect information that you voluntarily provide through our Online Platforms, such as your age and city of residence. This information does not identify you personally and is used solely to help us improve the effectiveness, functionality, and performance of our Online Platforms and the services we provide. From time to time, we may share aggregated or anonymized non-personal information with third parties for purposes related to the operation, maintenance, analysis, and improvement of our Online Platforms.

YOUR INTERACTIONS WITH US

We value your opinions and welcome feedback from our customers and visitors. Our Online Platforms may include features such as disclaimers, mailing lists, feedback forms, email communications, discussion forums, chat rooms, bulletin boards, or similar interactive services. Where you voluntarily disclose Personal Data through these features, we may collect and process such information in accordance with this Privacy Policy. Please note, however, that we cannot control and are not responsible for the use, disclosure, or processing of any Personal Data that you voluntarily make available to other users through these public or interactive features of our Online Platforms. We therefore encourage you to exercise caution when sharing Personal Data through these channels.

MAINTAINING THE ACCURACY OF YOUR PERSONAL DATA

We are committed to keeping the Personal Data we hold about you accurate, complete, and up to date. If you wish to review, update, correct, or request the deletion of the Personal Data you have provided to us, please contact us using the contact details provided below.

SECURITY OF YOUR PERSONAL DATA

We have implemented appropriate technical and organizational measures to protect your Personal Data against unauthorized access, misuse, loss, alteration, or disclosure. These measures are reviewed and updated as necessary to reflect technological advancements and evolving security standards.

MSIG Life Syariah is not responsible for the privacy policies or practices of third-party online platforms, including where:

1. You access a third-party online platform through a link available on our Online Platforms;
2. You are directed or linked to our Online Platforms from a third-party online platform.

We encourage you to read privacy policy of every online platform you visit so that you understand your rights and obligations, particularly before submitting any personal information through such third-party platforms. If you have any questions or concerns regarding a third-party online platform, you should contact the owner or operator of that platform directly.

CHANGES TO THIS PRIVACY POLICY

We may amend or update this Privacy Policy from time to time. If we make any material changes to this Privacy Policy or to the way we collect, use, or process your Personal Data, we will publish the updated Privacy Policy on this page.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your Personal Data.

Upon the publication of an updated version, this Privacy Policy will supersede all previous versions. The latest version made available on our Online Platforms shall constitute the applicable and effective Privacy Policy.

THIRD-PARTY ONLINE PLATFORMS AND LINKS

Our Online Platforms may contain links to third-party websites or other online platforms. MSIG Life Syariah is not responsible for the privacy practices, policies, or content of such third-party online platforms.

We encourage you to review the privacy policy of each third-party online platform you visit, as its privacy practices may differ from those of MSIG Life Syariah.

COOKIE POLICY

Cookies are small text files containing limited amounts of information that are stored on your device. We use cookies to enhance your browsing experience, personalize our Online Platforms, and provide content and advertisements that are relevant to your interests.

By using our Online Platforms, you consent to our use of cookies on your device. You may manage or disable cookies at any time through your device or web browser settings. However, please note that disabling certain cookies may affect the functionality and performance of our Online Platforms.

CONTACT US

If you want to contact PT MSIG Sharia Life Insurance Indonesia (MSIG Life Syariah) regarding this privacy policy, please reach us through contact center below:

Head Office
Sinarmas Land Plaza Sudirman, 7th Floor
Jl. Jend. Sudirman Kav. 21
South Jakarta 12920

Customer Service Hours:
Monday–Friday, 08.00–17.00 WIB (except national holidays)

Customer Care:
(021) 2650 8300
(021) 5060 9999

Email:
[email protected]