PT Asuransi Jiwa Sinarmas MSIG TBK (collectively referred to as “Company”, “we”, “us” or “our”) values your privacy and we are committed to protecting all Personal Data (as define below). Kept by us in accordance with relevant data privacy legislation, regulation, guidelines and/or orders in Indonesia (Collectively known as “applicable laws”).

This Privacy Policy (this “Policy”) sets out how your personal data (hereinafter “Personal Data”) may be handled by Company, its parent Company and its affiliates in relation to the App.

To the extent required by law, we will obtain your express consent for certain processing of your personal data. We will use your Personal Data to provide you with the products and/or services available through the App. You understand that your use of the App is voluntary. You do not have to participate in any of the social features in the App, and you can stop using the App and delete your account and all accompanying data at any time.

We process, handle and protect your Personal Data with the utmost care including but not limited to collecting, processing, analyze, storage, disclosure/transfer to other parties on/offshore, using and internationally transmitting Personal Data. In the processing your personal data we comply with applicable laws and regulations.

The App may contain hyperlinks to third-party websites. Company is not responsible for the content or privacy practices of any third-party. We recommend that you carefully review and consider the terms of use and privacy policy of all third-party websites prior to use.

PT MSIG Life Insurance Indonesia Tbk (formerly known as PT Asuransi Jiwa Sinarmas MSIG Tbk) is a company established and licensed with & supervised by OJK and member of Alternative Dispute Resolution Body Financial Service Sector.

Subject to applicable laws, you may also contact us, as described above, to inquire about your Personal Data held by us, withdraw consent to continued collection, processing, use or disclosure of your Personal Data where your consent has been obtained by Company as expressly required by law, to request access to or supplementation or correction of your Personal Data held by us, or to request a copy of your Personal Data and/or the most up-to-date version of this Policy.

Company will process your Personal Data real time after all your required data has been completed and received by Us. Company may collect and process the following Personal Data:

• Name
• Username
• E-mail address
• Date of birth
• Gender
• Biological age
• App data (including but not limited to avatar, steps, height, weight, body mass index, resting heart rate, hours of sleep, active calories burnt, stress and oxygen saturation (SPo2)) provided or uploaded by you either manually or generated by the App or through third-party wearable platforms such as (but not limited to) Garmin Connect or Apple HealthKit.
• Personal picture if you affirmatively choose to upload your picture in the App. Uploading a personal picture is not required for use of the App.
• Information about your performance, achievements and activity data (including time of last activity) on the Friends section (including the Activity Dashboard, Friends Leaderboard and tasks, challenges and competitions) if you affirmatively choose to participate to these social features. Participation in the social features is not required in order to use the App.

Additionally, Company may collect and process certain data, such as your language preferences, your time zone, IP address, device ID and the date and time when you use or synchronize the App.

Company collects your Personal Data when you provide your Personal Data to Company directly, when you use the App, and, if you choose to link your third-party wearable device such as Garmin Connect or Apple HealthKit to the App, when you use that third-party’s wearable platform. You understand that this Policy does not apply to the collection and processing of your Personal Data by any such third party’s wearable platform, which privacy policy may substantially differ from this Policy. We recommend that you carefully review and consider the terms of use and privacy policy of all third-party wearable platforms prior to use.

Company may collect and process your Personal Data for the following purposes:

• To establish your identity, set up your account and communicate with you concerning your account, including responding to any enquiries you may submit as well as sending emails to facilitate and verify your account creation.
• To provide the products and/or services to you, and information about those products and/or services. This includes fulfilling or meeting the reason for which the information is provided. For example, if you earn reward points under the App, we will use your Personal Data to provide reward points to you. We will also use your Personal Data for the purposes of calculating your biological age and helping you set and track your fitness goals.
• To allow you to participate in the social features such as the Activity Dashboard, Friends Leaderboard, Coach and competitions, should you affirmatively elect to participate in such activities.
• To execute marketing and related activities and to the extent that certain marketing activities require your consent under the relevant laws, we will seek your consent (see paragraph 5 below for more information).
• To send you (electronic) commercial messages (newsletters) with information about the products and/or services or request your feedback on use of the App through surveys and to the extent these require your consent under the relevant laws, we will seek your consent (see paragraph 5 below for more information).
• To review, analyze, monitor, maintain, secure and optimize the App and associated technologies.
• To comply with relevant laws and regulations.
• For testing, research, analysis and product and service development.
• Any other legal purposes required by laws and regulation and/or related authorities.

From time to time, we may use [your Personal Data] to send you marketing and other (electronic) commercial messages (newsletters) with information about [[our] products and/or services]]. To the extent we are required by applicable law, we cannot do so without obtaining your consent.

To the extent required by applicable law, we will obtain your consent before we will pass your Personal Data to any third parties for any marketing purposes.

If you have given us your consent to use your personal data for the above direct marketing purposes, you may opt out and withdraw your consent, free of charge, at any time, by contacting our Customer Service.

The Company respects the privacy of all its App users and takes steps to ensure that we protect the Personal Data you provide us. Company will not disclose and transfer any of your Personal Data to any third party without your consent, whether within or outside the local jurisdiction, except to:

• The Company’s group of Companies;
• Company personal advisers, vendors, suppliers, agents, business partners and/or financial institutions, in connection with any of the purposes above, including:  
  • Providing the App products and/or services to you.
  • Offering reward points and other contents to you.
  • Providing the products and/or services to you.
  • purposes of improving the products and/or services provided to you.
    These third parties may be located outside of the country in which you are located.
• Regulators, law enforcers, and/or bodies authorized according to law.

In addition, your Personal Data may be shared with other users if you participate in the Activity Dashboard, Friends Leaderboard, competitions and other social features, which are further described in Article 10 below.

From time to time, we may be compelled by legal action to release or disclose Personal Data, including in connection with a statutory reporting obligation, search warrant, court order, summons, subpoena, or bankruptcy or insolvency proceedings. We may also disclose Personal Data to government agencies in connection with a legal reporting obligation.

In accordance with the applicable laws and regulations, Company has taken appropriate and reasonable technical and organizational measures to safeguard the security of your Personal Data, including the following: Company stores Personal Data in a secure database that is protected by technical access controls and periodically reviews the information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to our systems.

Our App is not intended for users under the age of twenty (20) years old. If you are under age twenty (20), you may not use the App.

As a data subject, you may have certain rights that you can exercise according to the applicable laws, such as:

• right to request information on the processing of your Personal Data;
• right to access your Personal Data;
• right to rectify your Personal Data;
• right to cease the processing, deletion, and/or destruction of your Personal Data; and
• right to withdraw consent.

To exercise your rights, you may contact us through our Customer Service. We may refuse your request to exercise your rights tothe extent permitted under the applicable laws.

Reward Points. In addition to the collection and use of Personal Data as described in Article 4 of this Policy, reward points or “bolts” may be available to you based upon the Activity Dashboard, Friends Leaderboard, competitions and other features that Company may offer. Eligibility for App competitions and reward points will be communicated to you. Your Personal Data maybe used by the third parties listed in Article 6 for purposes of administering any competitions and distributing any resulting reward points that you may earn.

Surveys. Company will ask you to complete surveys during your use of the App. The results of these surveys may be shared with third party on an aggregated basis. When any results of your use of the App and survey responses are published or discussed with anyone outside of Company and its affiliates, no information will be included that would reveal your identity.

App Profile.If you do not wish to select an avatar that is available in the App, you may personalize your profile by setting a picture of your choosing, provided that the picture is work-appropriate and does not infringe upon the rights of others. You may remove your picture at any time in the App settings.

Friends Section.You may elect to join the Friends section of the App, where you will be able to add others who are also using the Friends section, individually connect and share your profile and daily achievements with your Friends. You will also be able to see how you compare with your Friends on the Activity Dashboard and Leaderboard. The Activity Dashboard has a total of 4 rankings: (a) biological age; (b) steps; (c) active calories burnt; and (d) the combination of (a), (b) and (c). In the Activity Dashboard and the Leaderboard, your Friends can see your name/username, avatar/profile picture, biological age, steps, active calories burnt, rankings and the last time the App was synchronized. If you want to stop sharing this data with your Friends and stop participating in the Activity Dashboard and/or Friends Leaderboard, you can revoke your access at any time in the App settings.

Friends Competitions. You can also create and participate in competitions with others who are using the Friends section. The Friends competition has the same 4 rankings: (a) biological age; (b) steps; (c) active calories burnt; and (d) the combination of (a), (b) and (c). You may elect to participate in each competition by accepting the invite to that competition. If you do not wish to participate, you are able to decline the invite when prompted in the App. Once you participate, your name, avatar, biological age, steps, active calories burnt, respective rankings and the last time your App was synchronized will be visible to all participants in the competitions.If you want to stop participating in the Friends competitions, you can terminate participation at any time in the App settings.

Coach. Where you choose to participate in the “Coach” feature your personal data may be used to provide you with guidance and support to complete your tasks and challenges. If you want to stop participating in the Coach feature, you can terminate your participation at any time in the App settings.

Company keeps your Personal Data or other data that you provide to us, whether or not provided via the App, for 10 (ten) years from your account is declared inactive by the company. After such period has expired, Company will destroy or de-identify Personal Data.

In all cases information may be held for

1. a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted/disposed once no longer required for the legal or regulatory purpose); or
2. a shorter period of retention period during which the data subject refuse to the processing of personal data and/or request that the personal data be deleted.

The Company reviews this Policy on a regular basis and may change it at any time. Whererequired under applicable law, we will inform you before we effectuate any change to this Policy. Otherwise, where permitted under applicable law, your continued useof the App will indicate that you have read and understood any updates of this Policy.

Questions about this Policy, the handling of your Personal Data, or our privacy or data protection practices, withdraw your consent, and/or exercise your rights you can contact our Customer Service via cs@msiglife.co.id .