Personal Data Protection and Privacy Notice

This Personal Data Protection and Privacy Notice (“Notice”) makes reference to the laws and regulations that apply under the jurisdiction of the Republic of Indonesia (“Applicable Law“) and applies to your use of this Website managed and maintained by bolttech, the Products (as defined hereinbelow) and Services (as defined hereinbelow) make available in this Website.

PT Bolttech Insurance Broker (“bolttech”) is fully committed to maintain integrity on personal data of our customers, employees, business partners, third parties or any other party whose data bolttech controls. We respect data privacy and safeguard the data entrusted to us. Furthermore, we strive to comply with applicable privacy laws and regulations of jurisdictions from which the personal data is collected, processed, used, disclosed, retained or destroyed. bolttech has a responsibility to take necessary precautions to keep personal data secure at all times and guard against unauthorised or unlawful processing in line with legal, regulatory and internal policy requirements.

You are advised to read and review this Notice thoroughly as it informs you as to how we collect, use, process your Personal Information. Please take note that bolttech may amend or update this Notice at any time to ensure that it is consistent with the industry trends and/or any changes in legal/regulatory requirements without prior notice to You. You agree to be bound by the prevailing terms of this Notice as updated from time to time.

For the purposes of understanding this Notice, the capitalised terms used in this Notice shall have the same meaning ascribed to them in this Notice:

1. “bolttech”, “we”, ”us” or “our” means PT Bolttech Insurance Broker (formerly known as PT Axle Asia), its affiliates and any member of bolttech group of companies;
2. “Personal Information” means any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual. Examples of Personal Information may include (these are merely examples, not all items relevant to you):|

   a. Name
   b. Date of birth
   c. National identification number
   d. Nationality
   e. Address (residential/mailing/e-mail)
   f. Phone number
   g. Biometric data such as facial image and fingerprints
   h. Computer’s IP address
   i. Cookies ID
   j. Person’s employment data
   k. Credit card number/bank account number.

3. “Products” means the products made available by bolttech and/or its business partners on the Website;
4. “Services” means the services made available by bolttech and/or its business partners on the Website;
5. “Website” means the website accessible at http://broker.bolttech.id

During your use of the Website, we will collect data and Personal Information from you, which may include but not limited to the following:

(a) Your name, date of birth, gender, nationality, educational background and marital status

(b) personal identification and authentication details, such as identification number/passport number, driving license, facial image and voice recording (for our customer service calls);

(c) your contact, mailing address, email address, network and, browsing behavior, personal interests and preferences;

(d) Personal Information required for marketing preferences and participation in surveys, promotional offers, competitions and contests;

(e) Information required for processing and handling product or service requests;

(f) Information necessary to process any communications with you such as customer service complaints, feedback, and suggestions;

(g) Information necessary to inform you about the benefits, changes, or improvements to the Products and Services; And

(h) Other personally identifiable information that you have provided to us in any form that you may have sent to us or in any other form of interaction between you and us.

If you do not provide us with the above-mentioned information, bolttech may not be able to provide you the Products and Services nor respond to any service requests. Furthermore, bolttech may not be able to serve you the notices and updates about new products, services, promotions or events.

It is important that the Personal Information bolttech hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with bolttech.

If you provide us with Personal Information relating to a third party by submitting such Personal Information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Information for the respective purposes.

bolttech may disclose the Personal Information collected from you to third parties, including service providers and partners engaged by bolttech to deliver its Products and Services or to carry out certain business activities on its behalf, such as, call centers, couriers, authorized repair centers, consultants, authorized agents, independent contractors, and government agencies or appropriate regulatory authorities without any intention to sell, rent or disclose your information to any third party without your consent. Some of these third parties may be located outside the Republic of Indonesia.

By (1) clicking “Yes” on our Notice pop-up or any web form referring to this Notice on any of our platforms, (2) submitting your Personal Information to us when signing up for an account on the Website, (3) browsing our Website, or (4) purchasing any of our Products and Services, you are agreeing to the terms of this Notice and you consent to the use of your Personal Information by bolttech.

We will not automatically collect any Personal Information that identifies a visitor to the Website. Your visit to the Website (save for purchase made by you) will record only the domain name server part of your email address and the pages visited.

The privacy principles

Data privacy relates to the appropriate collection, processing, use, retention, disclosure and disposal of the Personal Information that has been provided or entrusted by you. The privacy principles provide a privacy guidance and serves as the basis in protecting the rights of the individuals whose personal data has been provided to bolttech. bolttech privacy principles are:

1. Lawfulness, fairness, and transparency – bolttech ensures valid grounds when we collect your data, and bolttech ensures that the Personal Information shall not be processed in a way that is unduly detrimental, unexpected, or misleading.
2. Purpose limitation – bolttech ensures clear purpose to collect your Personal Information,
3. Data minimisation – bolttech ensures that bolttech will only collect Personal Information relevant to the Products and/or Services and to enable bolttech to provide our Services to you.
4. Accuracy – Personal Information shall be accurate and not misleading.
5. Storage limitation – bolttech ensures to retain the Personal Information only for the period mandated by the laws and regulations.
6. Integrity and confidentiality – bolttech ensures appropriate security measures in place to protect the Personal Information.
7. Accountability – bolttech assumes responsibility of the way we collect, store, and maintain the Personal Information.

 

How do we collect your personal information We collect Personal Information from you when:

(a) You register an account on the Website;
(b) You use any of our related services, such as subscribing to our newsletter, product notification etc;
(c) You browse our Products and Services or otherwise interact with our Website;
(d) You accept our cookies on your device;
(e) You interact with our customer experience team or other representatives via emails, telephone calls, letters, etc.;
(f) You participate in our promotions, initiatives or any request for additional Personal Information such as customer surveys;
(g) We receive references from business partners and third parties, for example, where they referred you to us to enjoy the benefits of a joint promotion or collaboration or to redeem a voucher you purchased through them;
(h) Your authorized representative submits your Personal Information to us for any purpose reasonably authorized by you, for example if such representative is purchasing our product or service for your use and enjoyment;
(i) Our third-party analytics and other service providers provide your Personal Information to us, which was collected and processed by them and disclosed to us pursuant to their separate policies; or
(j) When you voluntarily submit your Personal Information to us for any reason.

We usually do not collect your credit or debit card details, whether to process your payment or for customer service purposes. Your credit or debit card details are collected, processed and stored directly by our third-party payment processors pursuant to their terms of use and privacy policies. None of our debit or credit card details are stored with us. However, we may collect your bank account details to process the transactions and verify purchases made on our website.

Please ensure that all Personal Information submitted to us is complete, accurate, true and correct. Failure to do so may result in our inability to provide you with the Products and Services you have purchased.

 

How we use your personal information

We may use and disclose your Personal Information for purposes necessary to provide you with our Products and Services, including but not limited to:

(a) Register and maintain your user account and to verify your identity or age;

(b) Process your purchase for our Products and Services, process or collect your payment for the purchase;

(c) Handle, manage, deliver, or perform the Services you purchased or requested;

(d) Process your refunds in accordance with our Terms of Use and the relevant terms and conditions of the Products and Services;

(e) Provide you with supporting services and functions related to your user account such as brand, product or service notification;

(f) Communicate with you in relation to: (i) your queries, requests and feedback; (ii) material changes to our Website’s Terms of Use, Notice or other terms and conditions; and (iii) matters relating to the operation of your account;

(g) Personalize and improve your customer experience when you visit our Website;

(h) Monitor and enforce compliance with our Terms of Use including dispute resolution;

(i) Ensure our Website function properly and to improve their performance, by carrying out activities such as debugging, statistical analyses for optimizing our Website.

 

In addition, we may use and disclose your Personal Information for the following purposes (“Additional Purposes”):

 

(a) To send you marketing communication in relation to our sales, Products, Services, promotions or the Website;

(b) To send you marketing communication in relation to the sales, Products, Services, promotions of business partners;

(c) To deliver ads which are related to the Products and Services which may be of interest to you on the Website or other websites, apps or online platforms;

(d) To enable businesses to deliver ads which are related to their Products and Services which may be of interest to you ;

(e) To process your participation in our promotions, initiatives or any request for additional Personal Information such as customer surveys;

(f) To process your participation in our business partners’ loyalty, membership or point redemption programs;

(g) To conduct market and customer research, analysis or tracking;

(h) To promote our Products and Services on our Website;

(i) To manage the administrative and business operations of bolttech and complying with internal policies and procedures;

(j) To improve your customer experience across all touchpoints and training our customer experience team, such as by recording and monitoring phone calls; and

(k) Any specific purpose in relation to a particular Product or Service, which we may separately notify you on the Product or Service page.

 

We may also use your Personal Information: (i) for other purposes which are reasonably related to the Purposes and where we have obtained the relevant consent, the Additional Purposes; or (ii) in circumstances where such use does not require consent under applicable laws.

 

Please be informed that if you withdraw your consent for us to use and process your Personal Information for the Purposes and/or the Additional Purposes, we may no longer be able to provide you with the related and associated Products, Services or benefits.

 

To whom we share your personal information with

In relation to our use of your Personal Information for the Purposes and Additional Purposes, we may disclose or share your Personal Information to our:

(a) Employees, consultants, professional advisers, consultants or temporary workers;

(b) Business partners who sell the Products and Services or whom we enter into commercial collaboration with, including their employees, consultants, temporary workers;

(c) Payment processors, who process your payment on the Website;

(d) Logistics providers, such as courier services for pick-up and delivery services;

(e) Business partners who separately maintain an account with you for loyalty, membership or point redemption program;

(f) Agents, contractors or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimization, information technology, telecommunications, security or other relevant services, which require their collection, use or disclosure of your Personal Information;

(g) Affiliates, where you have subscribed to our mailing list, for direct marketing purposes or for the purpose of them conducting data processing on our behalf;

(h) Government institutions, or representatives, or to respond to requests from law enforcement authorities under Applicable Law; and

(i) Any other party whom you authorized us to disclose your Personal Information to.

 

We may also disclose your Personal Information: (i) for other purposes which are reasonably related to the Purposes and where we have obtained the relevant consent, the Additional Purposes; or (ii) in circumstances where such disclosure does not require consent under Applicable Law.

 

We will use our best endeavour to minimize disclosure of your Personal Information to the information necessary to perform the related Purpose or Additional Purpose.

 

Marketing and promotional material

We may send you direct marketing, advertisement, and promotional communications via push-notification app, message in Application, post, telephone call, short message service (SMS), and e-mail (“Marketing Materials”) if you have agreed to subscribe to our mailing list, and/or consented to receive marketing and promotional materials from us. You may opt out from receiving such marketing communications at any time by clicking on any “unsubscribe” facility embedded in the relevant message, or otherwise contacting us using the contact details stated below. Please note that if you opt out, we may still send you non-promotional messages, such as receipts, information which relates to your existing Products and/or Services or information about your account.

 

 

 

Acces and correction of personal information
Subject to the Applicable Law, you may request us for access to and/or the correction of your Personal Information in our possession and control, by contacting us at the details provided below.

 

When requesting for access or update to your Personal Information, we will require you to verify your identity before we act on the request. We reserve the right to refuse your requests for access to, or to correct, some or all of your Personal Information in our possession or control if permitted or required under any Applicable Law. This may include circumstances where the Personal Information may contain references to other individuals or where the request for access or request to correct is for reasons which we reasonably consider to be trivial, frivolous or vexatious.

 

Request to erase personal information

At all times, you have the right to request bolttech to erase your Personal Information. Please inform us if you wish for bolttech to erase your Personal Information and we will do so without undue delay.

 

Please note that we might not be able to provide our Services or the Products upon the deletion of your Personal Information.

Request to withdraw consent

If you wish to withdraw your consent for us to send you Marketing Materials, please inform us through the following means:

 

(a) To withdraw consent from receiving SMS promotions, please unsubscribes by following the steps provided in the promotional SMS;

(b) To withdraw consent from promotional emails, please click on the Unsubscribe link in the promotional emails;

(c) To withdraw consent from receiving Marketing Materials from other sources, please email our Data Privacy Officer at the email address provided below.

 

Once we receive notification that you wish to withdraw your consent for receiving Marketing Materials, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive Marketing Materials during this period.

 

If you withdraw your consent to receive Marketing Materials through a specific communication mode (e.g., SMS), we may still contact you for other purposes in relation to the Products and Services via other communication modes you have subscribed to (e.g., email).

 

You may withdraw your consent for the collection, use and / or disclosure of any of your Personal Information in our possession or control by submitting a written request to our Data Privacy Officers which details are provided below.

 

Please note that depending on the nature of the consent you seek to withdraw, we may not be able to continue to provide you with some or all of our Products or Services. We will process such a request within a reasonable time from receiving notice from you of your withdrawal of consent. Once the processing is complete, we will no longer collect, use and / or disclose your Personal Information, except to the extent where retention of your Personal Information is required for compliance, regulatory or other legal purposes.

 

Retention of personal information

Your Personal Information will only be held for as long as it is necessary to fulfil the purpose for which it was collected, or for as long as such retention is required or authorised by Applicable Law. We shall cease to retain Personal Information, or remove the means by which the Personal Information can be associated with you as an individual, as soon as it is reasonable to assume that the purpose for which that Personal Information was collected is no longer being served by retaining your Personal Information and retention is no longer necessary for legal or business purposes.

 

Please note that it is still possible where some of your Personal Information might be retained by the other party, including by the government institutions in some manner. In the event we share your Personal Information to the authorised government institutions and/or other institutions that may be appointed by the government authorities or have a cooperation with us, you agree and acknowledge that the retention of your Personal Information by the relevant institutions will follow their respective rules/regulations/policy on data retention. We shall not be liable for any such retention of your Personal Information. You agree to indemnify, defend and release us, our officers, directors, employees, agents, partners, suppliers and contractors from and against any and all claims, losses, liabilities, expenses, damages and costs (including but not limited to legal costs and expenses on a full indemnity basis) resulting directly or indirectly from any unauthorised retention of your Personal Information.

 

Cross border data transfer

When you use our Website in other countries where our Website is also accessible (“Designated Country”), we may transfer your Personal Information from the origin country (“Origin Country”) to the Designated Country in order to enable and ensure smooth customer experience when you are using our Website abroad. In such case, we will ask for your consent to transfer your Personal Data from the Origin Country to the Designated Country in order to ensure compliance with the Applicable Law.

 

Your Personal Information may also be stored or processed outside of your country by our personnel who work for us in other countries, or by our third-party service providers, vendors, suppliers, partners or contractors.

 

We will comply with the applicable laws and regulations and use all reasonable endeavors to ensure that our affiliates abroad and all such third-party service providers provide a level of protection that is comparable to our commitments under this Notice. bolttech ensures frequent monitoring of the security measures and controls provided by the third-party service providers.

 

Security of your personal information

Confidentiality of your Personal Information is of utmost importance to us. We will use all reasonable efforts to protect and secure your Personal Information against access, collection, use or disclosure by unauthorised persons and against unlawful processing, accidental loss, destruction and damage or similar risks. However, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secured. As such, while bolttech strives to protect your Personal Information, you acknowledge that we cannot guarantee the integrity and accuracy of any Personal Information which you transmit over the Internet, nor guarantee that such Personal Information would not be intercepted, accessed, disclosed, altered or destroyed by unauthorised third parties, due to factors beyond our control. You are responsible for keeping your account details confidential and you must not share your account details, including your password and One Time Password (OTP), with anyone and you must always maintain and fully responsible for the security of the device that you use.

 

Third party platforms

The Website and Marketing Materials may contain links to websites that are operated by third parties. We do not control nor accept liability or responsibility for these websites and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. Please consult the terms and conditions and privacy policies of those third-party websites to find out how they collect and use your Personal Information.

 

Advertisements contained on our Website or Marketing Materials operate as links to the advertiser’s website and as such any information they collect by virtue of your clicking on that link will be collected and used by the relevant advertiser in accordance with the privacy policy/notice of that advertiser.

 

Data breach incidents

Data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Information. This includes breaches that are the result of both accidental and deliberate causes.

 

Upon discovery of a data breach and in the event bolttech identifies that the data breach may impose a high risk against you, you shall be informed accordingly.

Bolttech shall use our best endeavours to investigate the data breach, including to work with the relevant regulators.

How to contact us

For any questions relating to your Personal Information or about this Notice, if you have a complaint regarding the collection, use or handling of your Personal Information by us or if you would like to obtain access and/or make corrections to your Personal Information, please contact our Customer Service Representative as stated in contact us page in the website.

 

You should clearly state in your emails and letters that you are making a data protection query, request or complaint in the subject line to ensure the matter is dealt with expediently. We will strive to deal with any query, request or complaint promptly and fairly.

 

Governing law

This Notice and your use of the Website shall be governed in all respects by the laws of Republic Indonesia.

 

Language

This Notice is issued in both English and Bahasa Indonesia. In the event of any inconsistencies or discrepancies between the English version and the Bahasa Indonesia version, the English version shall prevail.