Data Protection Notice

PT Allianz Global Investors Asset Management Indonesia

Privacy notice for Clients

For PT Allianz Global Investors Asset Management Indonesia (“we“, “us” or “our”), the protection of privacy and personal information (i.e. any information relating to an identified or identifiable individual person, “Personal Data“) is an important concern to which we pay special attention within all our business processes. We believe in transparency and are committed to being upfront about our privacy practices, including how we treat Personal Data.

This privacy notice describes how we processes Personal Data of legal representatives/agents/contact persons/employees of customers and business partners (“Clients”, “you” or “your”) who have entered or will enter into a contractual arrangement with us to obtain our services. It sets out how and which kind of Personal Data we may obtain, how we use, share and protect such data, the rights of Clients with respect to the Personal Data , and how to contact us about our data privacy practices.

Information about the processing of Personal Data collected when visiting our websites can separately be found in the Privacy Statement on our websites.

1. Who we are
   
   PT Allianz Global Investors Asset Management Indonesia is responsible for the processing of Personal Data of Clients for its own purposes as set forth in this privacy notice.
   
   Moreover, other entities within our group (which include our affiliates and entities under common control) as amended from time to time could become responsible for the processing of Personal Data of Clients, for example, for the purpose of marketing their own offerings. A list of the entities within our group with respective contact details is available upon request. This list may be updated from time to time without prior notice.
   
   To the extent two or more of our group entities process your Personal Data in a joint manner, we kindly ask you to address any queries you may have directly to the Data Privacy Officer whose details are set out in Section 11. The Data Privacy Officer will then forward your query to the group entity that is primarily responsible, if necessary.
2. Personal data obtained about you
   
   We will obtain your Personal Data when it enters into contracts with Clients and in connection with maintaining our Client relationships and providing services to Clients. If Clients provide us with Personal Data of their employees or agents, Clients have a legal obligation to inform them about this and obtain their consent, where legally required.
   
   We will also obtain your Personal Data from publicly available sources (for example from Client´s websites in anticipation of a prospective client relationship).
3. The types of Personal Data we may process
   
   We will process Personal Data related to you and to your accounts provided or otherwise known to us and/or the trustee/custodian of the relevant funds including but not limited to your names, postal or e-mail addresses, fax numbers, and phone numbers, employment information (e.g., job titles), gender, age, nationality, date and place of birth, your communication preferences (e.g. postal, by phone or email), your dealings with the funds and any other Personal Data in relation with your holdings.
   
   As a matter of practice, we will not collect any sensitive Personal Data (for example data concerning health, racial or ethnic origin) relating to you. If there is a need for us to process such sensitive Personal Data, we will only process such data in compliance with applicable data protection laws and regulations.
4. For what purposes we use the Personal Data obtained
   
   We will use your Personal Data:
   
   • To offer and provide products and/or services to you from time to time and administer, maintain, manage and operate such products and/or services which may include, without limitation, investments products and services including but not limited to derivatives, alternatives, securities, trading, commodity and equity sales;
   • To process, assess, determine and approve any application or request made by you for our products and/or services;
   • To introduce and/or cross-refer you to any of the divisions, affiliated companies and/or other business units within our group of companies, wherever situated, for which we may or may not be remunerated;
   • For any purposes in connection with any claims made by or against or otherwise involving you in respect of any products and/or services providing by us including, without limitation, to make, defend, analyse, investigate, process, assess, determine or respond to such claims;
   • To perform any functions and activities related to the products and/or services provided by us or by any of our external service providers in relation to the provision of our products and/or services including, without limitation, to audit, report (including analyses, materials and information generally in relation to investments and markets), conduct data analytics and market research using artificial intelligence technologies (e.g., machine learning) and profiling, operate our administration and support functions and carry out general servicing and maintenance of online and other services;
   • To perform any internal administration, support, information technology, regulatory or other internal functions or by any of our external service providers in furtherance of the above which may or may not be directly related to the products and/or services provided by us to you;
   • To design products and/or services for you and to promote, improve and further the provision of products and/or services by us and our agents;
   • To match and verify any data held by us relating to you from time to time for any of the purposes listed in this privacy notice;
   • To comply, where reasonably necessary, with any court orders, law, rules, any discovery procedures, regulations, code of practise, guidelines or requests binding on us, including but not limited to make disclosures of your Personal Data to regulators, governmental bodies, tax authorities or industry recognised bodies such as stock or futures exchanges, fiscal and financial authorities, securities and asset management associations, all of which may be within or outside Indonesia;
   • To comply, where reasonably necessary, with any obligations, requirements or arrangements that we have or may have in the future with local or foreign regulatory or tax authorities, whether imposed by law or assumed by us for the protection of our business, financial and other legitimate interests in or related to such jurisdictions, including but not limited to:
   • compliance with obligations binding on us and our affiliates pursuant to arrangements in relation to Chapter 4 of Subtitle A of the United States Internal Revenue Code of 1986 as amended or supplemented from time to time (“FATCA”);
   • establishing whether you are a citizen of the United States, resident in the United States for its federal income tax purposes or otherwise subject to tax in the United States and/or to substantiate whether your account has a US status for the purposes of FATCA; or
   • compliance with obligations binding on us and our affiliates in establishing identity of you and your beneficial owners;
   • To exercise any rights we have in connection with the provision to you of products and/or services;
   • To conduct identity, financial, money laundering and conflicts checks to prevent and detect fraud and crime including consideration of information related to political affiliations and criminal offences committed or alleged to have been committed; and/or
   • For any purposes relating to the above or any purposes in accordance with this privacy notice and other policies and procedures in relation to financial and investment services as set out in our statements, circulars, notices or other terms and conditions made available by us to Clients from time to time.
     
     To the extent this is required by applicable data protection laws and regulations, we will separately ask you for your consent and provide information as to what would happen if you do not give consent.
5. With and to whom we may share and transfer your Personal Data
   
   We share the Personal Data with:
   
   • Entities within our group (which include our affiliates and entities under common control) where this is reasonably necessary or desirable (for instance for purposes of fraud prevention or marketing, where legally permitted);
   • Service providers and their employees, officers, directors or agents, that we have retained to perform services on its behalf, including but not limited to outsourcing service providers, IT and cloud service providers; these service providers are not permitted to use the Personal Data for their own purposes but are required to solely process the Personal Data upon instructions received from us;
   • Any custodian, agent, broker, investment adviser, investment manager or external service provider to whom we delegate any of our duties, functions or obligations under any of our agreements with you or as permitted under any of our agreements;
   • Any person with whom we enter into any transaction in connection with the purchase or sale of any insurance or any other contractual protection or hedging with respect to your obligations under any of the products and/or services we provide or propose to you;
   • Any person with or through whom we may enter into any transaction as counter party, who is the issuer, vendor, purchaser or any agent of any of them;
   • Any person in connection with any claims made by or against or otherwise involving you in respect of any products and/or services provided by us;
   • Legal advisers and auditors including their employees, officers, directors or agents;
   • Fund services providers including their employees, officers, directors or agents;
   • Any person to whom we are under an obligation for disclosure under the requirements of any applicable laws, rules, regulations, codes of practices, guidelines or voluntary arrangements binding us including but not limited to any applicable regulators, governmental bodies or industry recognised bodies such as stock and futures exchanges, fiscal and financial authorities, securities and financial associations, (all of which may be within or outside Indonesia) and where otherwise required by law, including but not limited to any tax authority of any jurisdiction including but not limited to the United States Internal Revenue Service for the purposes specified above including but not limited to FATCA, or where we have reason to believe you may be a resident for tax purposes, citizen or otherwise subject to tax;
   • Any actual or proposed assignee, transferee, participants or sub-participants of our rights or business;
   • Other parties in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our or our group (which include our affiliates and entities under common control)’ business, assets or stock (including in any insolvency or similar proceedings), if applicable;
   • Subject to your consent, any agent, contractor or third party service provider who provides marketing or other related services to us in connection with the development and promotion of our business;
     
     In doing so it goes without saying that we comply with all applicable data protection laws and regulations.
6. With and to whom we may share and transfer your Personal Data
   
   The Personal Data of Representatives will be processed both inside Indonesia and outside Indonesia by the parties specified in Section 5 above, subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations. We will not disclose such Personal Data to parties who are not authorized to process them.
   
   Please note that other countries may have different laws regarding the protection of Personal Data. When your Personal Data is transferred from your own country to another country, the laws and rules that protect your Personal Data in the country to which your information is transferred to can be different (or less protective) from those in the country in which you reside. For example, the circumstances in which law enforcement can access Personal Data may vary from country to country.
   
   When transferring Personal Data internationally we make sure that we comply with applicable data protection laws and regulations, for example, by entering into agreements which will ensure that the recipients of your Personal Data maintain an adequate level of data protection.
7. How we protect Personal Data
   
   We maintain appropriate technical and organizational security measures and safeguards designed to protect Representatives’ Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use.
   
   All our employees and services providers are bound by confidentiality. Only authorised persons may process your Personal Data based on the "need-to-know" principle.
8. How long we retain Personal Data
   
   We store Clients’ Personal Data for as long as necessary to fulfil the purposes for which the Personal Data was collected or to fulfil legal obligations and as set forth in this privacy notice. Afterwards, we will delete the Personal Data in compliance with all applicable laws and regulations.
   
   Personal Data will only be used for the purposes for which it was collected unless your consent is obtained for its use for a non-related purpose.
9. Clients’ Rights
   
   To the extend permissible by applicable laws and regulations, Clients’ rights may include access to the Personal Data we process about you, the right to have such Personal Data corrected, erased or blocked, the right to restrict the processing of Personal Data, the right to withdraw consent at any time where your Personal Data is processed with your consent (without affecting the lawfulness of processing based on consent before its withdrawal), and the right to lodge a complaint with PT Allianz Global Investors Asset Management Indonesia. Where applicable under the relevant laws and regulations, Clients may exercise such rights by making a request (in written or electronic form) using the contact details set out in Section 11 below.
   
   Clients also have the right to object to the processing of their Personal Data for direct marketing (for example in relation to the receipt of newsletters) at any time with effect for the future by using the contact details set out in Section 11 below.
10. Updates to this Client Representative Privacy Notice
    
    We may update this privacy notice from time to time. We will notify Clients of any changes to this privacy notice on our websites or through other appropriate communication channels, such as emails to Clients, and we will require Clients to agree to the amended privacy notice. All changes shall be effective from the date indicated on the updated privacy notice, unless otherwise provided in the notification.
11. How to contact us
    Comments or inquiries about this privacy notice, requests to update information we have about you, or requests to exercise your rights as granted by applicable laws and regulations shall be sent to our Data Privacy Officer by postal mail to PT Allianz Global Investors Asset Management Indonesia, Data Privacy Officer, Compliance Department, Revenue Tower, Level 11, District 8, Jl. Jend. Sudirman Kav. 52-53, Jakarta 12190, Indonesia.
12. Language
    
    This privacy notice is made in both the English language and the Indonesian language. Both versions are equally authentic. In case of any inconsistency or difference of interpretation between the two versions, the relevant English language version will be deemed to be automatically amended to conform with and make it in line with the relevant Indonesian language version.

Last updated: February 22nd, 2022