Policy and Protection of Customer Personal Data

PT Bank MNC Internasional Tbk (hereinafter referred to as “MNC Bank” or “Bank”) is licensed and protected by the Financial Services Authority located in Central Jakarta and has branch offices spread across the territory of the Republic of Indonesia so it is necessary to maintain and protect the security of Customer Personal Data as users. MotionBank services. MNC Bank has prepared this Privacy Policy and Customer Personal Data Protection (hereinafter referred to as the “Policy”) to explain to Customers how to obtain, process, maintain, use, display, transmit, convey, delete and send Personal Data provided by Customers to MNC Bank on when downloading, uploading, accessing and using MotionBank services, namely referring to Law Number 27 of 2022 concerning Personal Data Protection (hereinafter referred to as “PDP Law”) as well as other applicable laws and relevant.

The Customer understands that the submission of Personal Data to MNC Bank is done voluntarily. If the Customer is unwilling to provide Personal Data, the Customer acknowledges that MNC Bank cannot process Personal Data for the purposes set out in this Policy, and this may result in MNC Bank being unable to provide services or products to or process the Customer’s transactions. It is important for Customers to read and understand every provision written in the Policy as a MotionBank user. Based on the matters above, MNC Bank implements the following Policy:

  1. Definition of Personal Data

In this Policy, what is meant by “Personal Data” is data, information and/or information in any form that is inherent and can be identified, either directly or indirectly through electronic or non-electronic systems from time to time.

  1. Acquisition and Collection of Personal Data

MNC Bank as the Personal Data Controller places great emphasis on Customer Personal Data and guarantees that it will maintain confidentiality when collecting Personal Data which is limited to the purposes of processing Personal Data as regulated in this Policy and the provisions of applicable laws and regulations. MNC Bank collects customer personal data when:

  1. Given by the Customer directly for any reason;
  2. Use previous MNC Bank services and/or products;
  3. Register, access services and make transactions via MotionBank;
  4. Give consent to MNC Bank to collect Personal Data from electronic devices such as location information, cookie data;
  5. Make changes and/or update Personal Data;
  6. Requested by MNC Bank (if necessary) from time to time; or
  7. Provide Personal Data to Business Groups and/or other third parties who are MNC Bank partners and collaborate with MNC Bank.

The categories and types of Customer Personal Data that can be processed are as follows:

  1. Personal profile identification data, namely in the form of full name, Population Identification Number, gender, nationality, place and date of birth, birth mother’s maiden name, alias/nickname, religion, voice recording, image recording, photo and/or biometric data ;
  2. Correspondence data, which can be in the form of address according to the Resident’s Identity Card, address and domicile status, electronic mail address (email), telephone/cell phone number.
  3. Education and/or employment data, which can be in the form of education level, type of work, business field, position, division, year of start of work/business, name of company/agency where you work, address of work place, employment status.
  4. Family data, which can include marital status, partner’s name, number of children and number of dependents;
  5. Financial data, which can be in the form of account numbers, sources of income, total monthly/annual income, total monthly/annual expenses, transaction data, credit/financing data, investment-related data, asset-related data, collateral-related data, and taxation data as well as service data from other financial services that the Customer receives;
  6. Digital activity data, which can be in the form of customer activity on the Bank’s application, and interaction of the Bank’s application with other applications on the customer’s electronic devices; and/or
  7. Customer banking transaction data at MotionBank; and/or
  8. Other data that can be classified as Personal Data.

  1. Use of Personal Data

MNC Bank may process and/or use Personal Data for the purposes as stated below:

  1. To provide, design and/or develop services, banking facilities, products or services, statistical analysis including the use of new technology, and use of MNC Bank services as well as informing customers if there are any changes to the service.
  2. For profiling and scoring of customers to improve the Bank’s services and risk management.
  3. For marketing, namely offering products and/or services, promotions or information of interest to customers sent by MNC Bank and/or MNC Bank business partners to customers via physical mail, electronic mail, short message service, telephone, fax, other means correspondence and other media for conveying official MNC Bank information that is appropriate and subject to applicable laws and regulations.
  4. For the implementation of MNC Bank business which involves consultation with professional advisors or external auditors of the Bank, including legal advisors, financial advisors and consultants, Business Group companies, and any party bound by obligations to maintain confidentiality with MNC Bank.
  5. To fulfill the Know Your Customer (KYC) requirements or the principle of getting to know your customer, the Bank’s risk mitigation efforts, as well as implementing verification/authentication of the correctness of customer data based on applicable laws and regulations.
  6. To fulfill laws and orders from regulators, law enforcement officials and other authorized agencies.
  7. For other purposes in accordance with the Bank’s internal policies and regulations, or in accordance with the terms and conditions governing the relationship between the Bank and its Customers, which are implemented in accordance with applicable laws and regulations.

  1. Personal Data Processing

Based on the consent of the Customer, the Bank may act as a controller of Personal Data to process the Customer’s Personal Data where the purpose of the implementation of the Customer’s Personal Data Processing is among others:

  1. Providing and processing the Services that the Customer chooses or has which include:
    1. Provision of banking services and information related to such services
    2. Implementation of the provisions of laws and regulations, including the application of the Customer Due Diligence (CDD) principle, the implementation of the Anti-Money Laundering Program, Prevention of Terrorism, Prevention of the Financing of the Proliferation of Weapons of Mass Destruction, and the Anti-Bribery and Corruption Policy in connection with the provision of services to the Customer;
    3. Responding to and resolving requests from the Customer in connection with the provision of services;
    4. Modifying, improving, and/or developing services, including updates and/or adjustments to applications/systems related to the services; and/or
    5. Fulfilling other needs as necessary as long as they are related to the provision/processing of services to the Customer.
  2. Implement and improve operational activities, and comply with the provisions of applicable laws and regulations, including:
    1. Conduct surveys, research and studies related to the provision of services, including producing analytical data generated through data analysis and/or usage patterns for the purposes of research, analysis, testing, product development, and cooperation with third parties;
    2. Collect payments for the provision of services;
    3. Conduct activities related to accounting, auditing, taxation, and reconciliation related to the provision of Services, as well as internal administrative processes;
    4. Carry out obligations based on agreements to Customers and/or to related third parties (including but not limited to vendors and partners);
    5. Prevent, detect, investigate any suspicious transactions, criminal acts, or prohibited activities including based on applicable laws and regulations;
    6. Communicate with Customers through various media, including to respond to questions, comments, or complaints;
    7. Process Customer participation in any production activities, contests, games, promotions, polls or surveys;
    8. Performing other internal activities necessary to provide services, such as troubleshooting software, bugs, operational issues, conducting data analysis, testing, and research, and to monitor and analyze usage and activity trends;
    9. Fulfilling requests in connection with law enforcement and protecting the rights of MNC Bank and/or Customers;
    10. Fulfilling other needs as required in providing services as long as they are related to the implementation/improvement of operational activities and complying with the provisions of applicable laws and regulations.
  3. Product and promotion offers that include service offers, products, prize draws, events, or other forms of promotion that are understood to be in accordance with the needs and profile of the Customer. MNC Bank can convey offers for products/services owned or provided by MNC Bank and/or third parties), through various media and/or methods, both verbally and in writing, including through push notifications, social media, instant messaging applications (eg WhatsApp), SMS, telephone calls, emails, brochures, or other relevant electronic and non-electronic media in accordance with applicable provisions
  4. MNC Bank can process Customer Personal Data if instructed or required by an authorized government agency, for the purposes as stated or regulated by applicable laws and regulations.

Processing of Customer Personal Data may be carried out by a third party so that MNC Bank can share/disclose Customer Personal Data to a third party for further processing of Customer Personal Data in accordance with the purpose and basis for processing Customer Personal Data by MNC Bank. Processing carried out by third parties on behalf of MNC Bank is carried out for purposes in accordance with the basis of processing or consent that has been given by the Customer.

  1. Customer Rights as Personal Data Subjects

Customers have the following rights as Personal Data Subjects:

  1. The right to obtain information about the clarity of the identity of the party requesting Customer’s Personal Data, the purpose of the request and the use of Customer’s Personal Data
  2. The right to complete, update, and/or correct errors and/or inaccuracies in Customer’s Personal Data in accordance with the purpose of processing Personal Data. However, MNC Bank cannot accommodate changes to Personal Data if MNC Bank believes that the changes will violate the provisions of laws and regulations and/or any legal requirements that cause the information to be incorrect.
  3. The right to obtain access and obtain a copy of Personal Data in accordance with the provisions of laws and regulations and MNC Bank policies in an appropriate or readable form, where MNC Bank has the right to charge a reasonable fee to fulfill the request.
  4. The right to terminate processing, delete and/or destroy Personal Data in accordance with the provisions of laws and regulations. Customers may not be able to use and/or receive MNC Bank services if the Customer deletes and/or destroys Personal Data in part or in full. MNC Bank’s obligation to delete and destroy Customer Personal Data is exempted from:
    • National defense and security interests;
    • Law enforcement interests;
    • Public interests in the context of state administration; or
    • The interests of supervising the financial services sector, monetary, payment systems and financial system stability carried out in the context of state administration.
    • Statistical and scientific research interests;
    • The need to implement the provisions of applicable laws and regulations, for example related to the implementation of the Customer Due Diligence (CDD) process and/or preventing criminal acts;
    • The reason for the request is not relevant to the Bank’s Personal Data processing activities or to the Customer as the subject of Personal Data;
    • Endangering the security, physical health, or mental health of the subject of Personal Data and/or others; and/or
    • Impact on the disclosure of Personal Data belonging to others
  5. Right to withdraw consent to the processing of Customer’s Personal Data that has been given to MNC Bank. Customers are deemed to have understood and accepted the consequences of withdrawing consent to the processing of Personal Data.
  6. Right to file objections to the results of processing Customer’s Personal Data that have legal consequences or have a significant impact on Customers.
  7. Right to postpone or limit the processing of Customer’s Personal Data proportionally in accordance with the purpose of processing Customer’s Personal Data. However, Customers must understand that requests to postpone or limit such processing may affect MNC Bank in providing products or services to Customers as well as contractual relationships that have been made by MNC Bank with Customers or MNC Bank with other third parties, including the possibility of cessation of services received by Customers and/or termination of one or more Customer agreements with MNC Bank and/or violation of one or more Customer obligations under the agreement with MNC Bank.
  8. Other rights in accordance with laws and regulations related to the processing of Customer Personal Data as long as they are regulated in applicable laws and regulations.

  1. Storage and Deletion or Destruction of Personal Data

MNC Bank ensures that Personal Data submitted by Customers will be stored securely in accordance with MNC Bank’s internal policies and applicable laws and regulations in the Republic of Indonesia. MNC Bank will store Customer Personal Data submitted by Customers as long as necessary to fulfill the purposes stated in this Policy, in accordance with the need to fulfill MNC Bank’s obligations to Customers, protect or defend the interests of MNC Bank and its Customers or as required by applicable laws.

To the extent that it does not conflict with applicable laws and regulations, MNC Bank will stop storing and will immediately delete and/or destroy Customer Personal Data after it is deemed that processing of Customer Personal Data is no longer necessary based on the purposes stated in this Policy.

Deletion or destruction of Customer Personal Data at MNC Bank can be carried out in accordance with the following provisions:

  1. the purpose of processing Customer Personal Data has been achieved and the Personal Data is not reused in accordance with the Bank’s retention policy or in accordance with the provisions of laws and regulations governing such provisions; or
  2. at the request of the Customer, unless otherwise specified by the provisions of applicable laws and regulations.

  1. Disclosure of Personal Data

MNC Bank understands to comply with the provisions of this Policy and will continue to maintain confidentiality, but for the purposes as set out in the Policy. The Customer understands that MNC Bank has the right to provide Customer information to third parties with the following provisions:

  1. Permitted or approved by the Customer;
  2. Required, determined or required to carry out MNC Bank’s compliance with the provisions of applicable laws and regulations.

  1. Revocation of Consent

As long as it does not conflict with applicable laws and regulations, the Customer has the right to withdraw or revoke consent either in part or in whole for the provision of Personal Data which can be submitted to the Bank in writing addressed via email as follows: cs@motionbank.id

  1. Restrictions

The Customer understands that in the event of the circumstances as stated below, it is a situation that occurs beyond the capabilities of MNC Bank:

  1. An act of nature or unforeseen circumstances has occurred, resulting in damage or destruction of equipment and/or systems used to secure, store or process Customer Personal Data;
  2. Personal Data has been available or can be found by the public before the Personal Data is submitted to MNC Bank;
  3. MNC Bank has made its best efforts to verify, secure and protect Personal Data, and in the event of unauthorized access, hacking, misuse, modification, change, interference;
  4. MNC Bank has made its best efforts to verify, secure and protect Personal Data, and in the event of unauthorized access, hacking, misuse, modification, change, interference;
  5. Misuse of Personal Data and information caused by criminal acts, fraud or any criminal act or wrongful actions of third parties not under the control or instructions of MNC Bank.

  1. Contact Us

If there are questions or if there is something that is unclear, Customers can contact the MNC Bank Call Center at 1500188 or can send an electronic letter (email) addressed to: cs@motionbank.id

  1. Policy Changes

MNC Bank may change, supplement, and/or replace this Policy from time to time (with notification to the Customer) to ensure that this Policy is in line with the procedures and practices implemented by MNC Bank in processing Customer Personal Data, including to comply with the provisions of applicable laws and regulations.

  1. Others
    1. This Policy is governed and interpreted in accordance with the laws of the Republic of Indonesia.
    2. This Policy has been adjusted to the provisions of applicable laws and regulations including the regulations of the Financial Services Authority.