Notice Regarding the Transfer and Processing of Personal Data

The transfer is carried out as part of the merger process to ensure the continuity of business operations and services, the fulfillment of contractual obligations, the management of investments, the fulfillment of the rights and obligations of the parties, and compliance with legal obligations under applicable laws and regulations.

This transfer is not intended to expand the use of Personal Data beyond legitimate and relevant processing purposes.

Types of Personal Data to Be Transferred
Depending on the need and relevance, the Personal Data that may be transferred includes:
•    Identity and contact data
•    Account data and/or transaction-related information
•    Data and information related to ownership and/or investments
•    Data related to contractual and administrative relationships
•    Data required for the implementation of Customer Due Diligence and Know Your Customer

•    Data required to fulfill Anti-Money Laundering and Counter-Terrorism Financing obligations
•    Data related to correspondence and services provided to customers or investors
•    Data required to comply with legal and regulatory obligations
•    Other Personal Data that has been lawfully obtained and processed for purposes relevant to business activities.
 

Purposes of Data Processing Following the Merger
Following the transfer, PT Mandiri Manajemen Investasi will continue to process Personal Data for the following purposes:
•    To continue providing services and managing relationships with customers and investors
•    To carry out investment management and investment product administration activities
•    To fulfill agreements and honor the rights and obligations of the parties
•    To comply with obligations under applicable laws and regulations

•    To fulfill reporting obligations to the Financial Services Authority (OJK), the Indonesian Central Securities Depository (KSEI), regulators, institutions, and/or other competent authorities
•    To conduct Customer Due Diligence and fulfill obligations related to the prevention and eradication of money laundering and terrorist financing
•    Carry out risk management, information security, auditing, oversight, and compliance
•    Fulfill other purposes that have been communicated to the Data Subject and/or are permitted under applicable laws and regulations
 

Data Controller and Protection of Personal Data

Until the merger becomes effective, PT BNI Asset Management remains the data controller and is responsible for the processing of Personal Data under its control.

After the merger becomes effective, PT Mandiri Manajemen Investasi will assume and continue the control and processing of the transferred Personal Data in accordance with the applicable functions, purposes, and legal basis for processing.

PT BNI Asset Management and PT Mandiri Manajemen Investasi are committed to safeguarding the security and confidentiality of Personal Data. The processing of Personal Data will continue to be carried out in a limited, specific, legally valid, and transparent manner, and in accordance with the purposes of such processing.

Rights of Data Subjects

Data subjects may continue to exercise their rights in accordance with applicable laws and regulations, including the right to:
•    Obtain information regarding the processing of Personal Data
•    Update and/or correct Personal Data
•    Obtain access to and a copy of Personal Data in accordance with applicable regulations
•    Submit a request for the termination, deletion, and/or destruction of Personal Data

•    Withdraw consent if the processing is based on consent and there is no other lawful basis for processing
•    File an objection or other request in accordance with the rights of the Data Subject under applicable regulations

The exercise of such rights remains subject to the exceptions and provisions of applicable laws and regulations, including the obligation to retain Personal Data for a specified period of time.

Notice Following the Merger

Once the merger becomes effective, PT Mandiri Manajemen Investasi will provide further notice regarding the transfer of Personal Data and the processing of Personal Data by PT Mandiri Manajemen Investasi.

Personal Data Protection Contact

Prior to the merger becoming effective, any questions, requests, or exercises of rights related to Personal Data may be directed to:

Translated with DeepL.com (free version)