Privacy Policy

/ Privacy Policy

Introduction

PT Multipolar Technology Tbk (“MLPT” or “We” or “Us”) is committed to protecting the security and confidentiality of Your Personal Data. This Notice of Personal Data Protection Policy (“Notice”) explains how We obtain, collect, use, store, correct, update, transfer, disclose, protect, delete, and/or destroy Your Personal Data.

In carrying out the Processing of Personal Data, We refer to the prevailing laws and regulations, including but not limited to Law of the Republic of Indonesia Number 27 of 2022 concerning Personal Data Protection, together with its amendments and/or updates and/or its implementing regulations, as well as the information security standards applicable within MLPT, including the principles of ISO/IEC 27001:2022 Information Security Management System.

This Notice applies to every individual whose Personal Data is processed by MLPT, including website visitors, customers, prospective customers, business partners, vendors, event/webinar participants, prospective employees, employees, representatives of legal entities, office visitors, and/or other parties who interact with MLPT.

 

Definitions

In this Notice, the following terms shall have the following meanings:

  1. You or Your or Personal Data Subject means an individual to whom Personal Data is attached and whose Personal Data is processed by MLPT.
  2. Personal Data means data about an identified or identifiable individual, whether on its own or in combination with other information.
  3. Processing of Personal Data means any activity carried out in relation to Personal Data, including the collection, use, storage, correction and updating, transfer, disclosure, deletion, and/or destruction of Personal Data.
  4. Personal Data Controller means any person, public body, and/or international organization acting individually or jointly in determining the purpose of and exercising control over the Processing of Personal Data.

 

Personal Data that We Process

The Personal Data that We may process depends on Your relationship and interaction with MLPT, which may include:

  1. identity data, such as full name, position, title, division or work unit, signature, or other relevant identity information;
  2. contact data, such as email address, telephone number and/or WhatsApp number, domicile address and/or correspondence address;
  3. company or business relationship data, such as company name, office address, line of business, position/authority information, and other relevant information;
  4. technical data and digital activity, such as Internet Protocol (IP) address, device type, browser, access logs, cookies information and similar tracking technologies; and/or website usage activity;
  5. recruitment and/or employment data, such as curriculum vitae (CV), educational/employment history, identity documents, emergency contact data, bank account data, tax data, attendance data, and other required data; and
  6. physical security and visit data, such as guest data, visit time, contact number, and Closed-Circuit Television (“CCTV”) recordings.

MLPT only processes specific Personal Data where necessary, relevant, and supported by a lawful basis for processing.

 

How We Obtain and Collect Data

We may obtain and collect Your Personal Data through online/offline forms, communication with MLPT, event or webinar registration, use of the website (including cookies information and system logs), the company or institution You represent, legitimate partners/vendors/third parties, publicly available sources, as well as MLPT’s physical security systems, including guest records and/or CCTV.

 

Purposes of Processing Personal Data

MLPT processes Your Personal Data for the following purposes:

  1. to provide, manage, support, and enhance MLPT’s information technology services, products, and solutions;
  2. to respond to Your questions, requests, feedback, complaints, or grievances;
  3. to conduct communications relating to MLPT’s products, services, events, webinars, updates, or other information;
  4. to conduct marketing, promotion, surveys, analysis, and service development;
  5. to organize events, webinars, surveys, or other MLPT activities;
  6. to carry out business relationships, cooperation, transactions, procurement, offers, or agreements;
  7. to conduct recruitment processes, employment administration, and Human Resources management;
  8. to maintain the security of MLPT’s systems, networks, information technology infrastructure, offices, work locations, and assets; and/or
  9. to fulfil legal, audit, compliance, risk management, and information security obligations, dispute resolution, or the defense of legal claims.

 

Basis for Processing Personal Data

MLPT’s Processing of Personal Data is carried out on the basis of one or more of the following: Your valid consent, the performance of a contract/agreement, compliance with legal obligations, MLPT’s legitimate interest (while giving due regard to MLPT’s interests and Your rights), the protection of vital interests, and/or the public interest, to the extent relevant and permitted under the prevailing laws and regulations.

 

Sharing of Personal Data with Third Parties

MLPT may disclose Your Personal Data to third parties on a limited basis, in accordance with the purpose of processing, a lawful basis for processing, and the prevailing laws and regulations. Such third parties may include affiliated companies, technology, cloud, hosting, and data center service providers, vendors, business partners, consultants, professional advisors, event/webinar organizers, operational support service providers, regulators, government authorities, law enforcement officials, courts, or other parties permitted under the prevailing laws and regulations.

MLPT will take reasonable steps to ensure that third parties maintain the confidentiality and security of Your Personal Data. MLPT will not sell or rent out Your Personal Data.

 

Transfer of Personal Data Outside the Territory of Indonesia

Where necessary, MLPT may transfer Personal Data outside the territory of Indonesia. Such transfer will be carried out in accordance with the prevailing laws and regulations, including by ensuring an adequate level of Personal Data protection and/or a lawful protection mechanism. Where required by applicable law, MLPT will obtain Your consent.

 

Security and Confidentiality of Personal Data

MLPT implements reasonable technical and organizational security measures to protect Personal Data from unauthorized access, use, disclosure, alteration, loss, destruction, or processing, and/or other security risks. Such measures may include access restrictions, authentication, encryption, system monitoring, network and/or system security, security audits, oversight of parties involved in the processing, and incident handling procedures in accordance with applicable standards, including ISO/IEC 27001:2022.

 

Storage and Retention of Personal Data

MLPT stores Personal Data for as long as necessary to achieve the purpose of processing, to comply with legal or contractual obligations, and for audit, bookkeeping, compliance, dispute resolution, defense of legal claims, or other legitimate interests. Once the retention period has ended or the Personal Data is no longer required, MLPT will delete and/or destroy the Personal Data in accordance with applicable provisions.

 

Your Rights as a Personal Data Subject

In accordance with the prevailing laws and regulations, You have the right to obtain information, to access and obtain a copy of Your Personal Data, to correct or update Your Personal Data, to withdraw Your consent, to delete or destroy Your Personal Data, to restrict the processing thereof, to submit objections and/or complaints, to request the portability of Your Personal Data, and to file a lawsuit or claim for damages in accordance with the prevailing laws and regulations.

The exercise of the foregoing rights may be limited or excluded in certain circumstances in accordance with the prevailing laws and regulations.

 

Cookies and Tracking Technologies

MLPT’s website may use cookies and similar tracking technologies to ensure the functionality of the website, enhance security, analyze website usage, store preferences, and improve the user experience. You may set, restrict, or refuse cookies through Your browser or device settings, provided that doing so may affect certain functions of MLPT’s website.

 

Changes to This Notice

MLPT may update or amend this Notice from time to time in line with developments in its business activities, services, technology, information security practices, and/or the prevailing laws and regulations. Any changes will be notified through MLPT’s official website or other appropriate means of communication.

 

Contact Us

If You have any questions, requests, objections, or complaints, or wish to exercise Your rights as a Personal Data Subject, You may contact Us through:

PT Multipolar Technology Tbk

Email: dataprotectionofficer@multipolar.com

Office Address: Sopo Del Office Tower & Lifestyle, Tower B, 18th Floor, Jl. Mega Kuningan Barat III, Lot 10.1–6, Kawasan Mega Kuningan, South Jakarta 12950, Indonesia.

Website: www.multipolar.com

MLPT will follow up on every question, request, or complaint in accordance with the prevailing laws and regulations and MLPT’s internal policies.