SEKISUI POLYMATECH INDONESIA (“Sekisui”, “we” or “us”) greatly appreciates the opportunity to work with you. We value your trust and strive continually to justify that trust.

As you likely will have heard, Law No. 27 of 2022 on Personal Data Protection (“PDP Law”) is effective from October 17, 2022, bringing with it new requirements for the handling of personal data, including personal data of Sekisui’s clients and business partners such as any prospective and current customers, suppliers, contractors, agents, or consultants.

Sekisui is committed to protecting the privacy and security of your personal data. This data protection notice describes how we collect and use personal data about you and individuals affiliated with you prior to, during, and after your relationship with us. It applies to all prospective and current clients and business partners. As updated from time to time, this notice will continue to apply after our work for you concludes.

With respect to certain individuals in Republic of Indonesia, Sekisui may be considered a data controller under the PDP Law as it may vary from time to time. This means that we are responsible for deciding how we hold and use personal data about you. We are providing this notice pursuant to the PDP Law. This notice does not form part of any contract to provide legal services. We may update this notice at any time.

Terms used in this notice

In this notice, Personal Data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to physical, psychological, genetic, mental, economic, cultural or social identity of that natural person.

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, and Process and Processed shall be construed accordingly.

Sensitive Personal Data means information that reveals criminal records, health data or information, children data, financial data, genetic data, biometric data, or any other data as defined by applicable laws and regulations, of a natural person.

The Personal Data that Sekisui collects

Depending on the requirements of a particular matter, Sekisui may receive the following Personal Data about you, which includes Sensitive Personal Data:

• Your name;
• Your contact details (e.g. postal address, personal or business email address, telephone number, mobile number);
• Your SNS and Chat tools information (Facebook ID, WhatsApp ID etc.);
• Your date of birth;
• Your gender;
• Your race, ethnicity or religion;
• Your nationality;
• Your bank details;
• Your governmental identification numbers;
• Information relating to your health;
• Information relating to your insurance;
• Information relating to your taxes;
• Your educational history and qualifications;
• Your employment history;
• Your position and job title;
• Information relating to your employment and work performance;
• Information relating to your travel arrangements;
• Your passport and visa details;
• Premises security information, which may include access logs and CCTV or security cameras footage;
• Images and photographs;
• Information relating to your family;
• Information relating to whistle-blowing system and other legal matters;
• Log files and device information (IP address, the date and time of the request, the requested URL etc.);
• Cookies (in case you access and use this website); and
• Other information relating to the matters which Sekisui acts for you.

In addition to Personal Data that you provide to Sekisui, Sekisui may obtain Personal Data about you from others, including third-party databases in the course of performing required checks such as anti-money laundering or sanctions checks. Depending on the circumstances of a particular matter, we also may obtain Personal Data from other parties in connection with our work on your behalf.

Why Sekisui uses your Personal Data

The legal basis that Sekisui relies upon for Processing your Personal Data, whether such Processing occurs before, during or after your relationship with Sekisui, will fall into one of the following categories:

• The performance of any of Sekisui’s obligations under your engagement with Sekisui as well as Sekisui’s policies or legal obligations (including Anti-Money Laundering and sanctions checks);
• the legitimate interests of Sekisui, including checks necessary to protect Sekisui’s financial position; and
• where applicable, your provision of consent for Sekisui to Process your Personal Data in a certain way.

Sekisui may use your Personal Data, including Sensitive Personal Data, for the following purposes:

• administering arrangements concerning your relationship with Sekisui;
• any communication for any business opportunities or support with you;
• carrying out checks prior to or during the course of your relationship with Sekisui, such as Anti-Money Laundering or sanctions checks;
• conducting Sekisui’s ongoing business;
• processing any payments received on your behalf, including any legal obligations relating to such payments;
• providing you and your representatives with marketing information about Sekisui and our services;
• safety and security in our premises;
• recruitment activity;
• provision, improvement, development and security of this website; and
• analysis for the use of this website by cookies.

We will not Process your Personal Data, for any other purposes incompatible with the purposes mentioned above.

We use the information and data generated by cookies to analyze the use of this website. This enables us to find out more about the number of visits to a web page, user behavior or the length of your stay and to draw conclusions about which content on this website is particularly interest­ing and which is less interesting for visitors. We may take this into account in future updates and re­designs of this website.

For these purposes, we use the analytical service Google Analytics of Google, LLC, 1600 Amphithea­tre Pkwy, Mountain View, CA 94043, USA. This is a tool that provides us with information about the use of this website. The information and data collected form these cookies are transferred to Google. Google will use this information to compile aggregated evaluations of the use of this website. Google may also transfer this information to third parties when required to do so by law, or where such third parties process the information on Google’s behalf.

Additionally, we have activated the IP anonymization of Google Analytics. Before the IP address is transmitted to Google’s servers in the US, it is shortened within Republic of Indonesia. This procedure makes the IP address untraceable. Only in exceptional cases the complete IP address is transmitted to a Google server in the US and shortened there. The IP address transmitted by your browser as part of Google Analytics will not be combined with other data from Google.

Further Information about Google Analytics can be found under https://marketingplatform.google.com/intl/en_uk/about/analytics/.

If you fail to provide Personal Data

If you fail to provide certain Personal Data when requested, Sekisui may not be able to perform the services that it has agreed to provide for you, or may be prevented from complying with our legal obligations (such as running required checks).

With whom Sekisui will share your Personal Data

Sekisui will not sell your Personal Data to third parties.

For the provision of our services Sekisui may share your Personal Data on a strictly need-to-know-basis with affiliate companies or parent companies of Sekisui.

Sekisui may sometimes share your Personal Data with its trusted service providers and other third parties who perform services and functions on Sekisui’s behalf to support its interactions with you, including for example technology providers, disclosure and discovery vendors, experts, and consultants.

Sekisui may also have to disclose your Personal Data to comply with a legal obligation imposed on it.

From time to time, Sekisui may disclose your Personal Data to organizations for the purposes of fraud and credit risk reduction. Sekisui may also share your Personal Data with its legal advisers for the purposes of obtaining advice and the protection of its legal rights.

Where Sekisui stores your Personal Data and how it secures your Personal Data

Sekisui may disclose and transfer your Personal Data to foreign countries, in order to achieve certain purposes. It should be noted that there are possibilities that each foreign country to which your Personal Data will be transferred and stored has its own data protection law with inadequate measures and standards, which you may not be afforded some of the rights conferred upon you in Republic of Indonesia. To safeguard your Personal Data, Sekisui maintains appropriate physical, electronic and procedural safeguards. However, please note that the transmission of information via the internet is not completely secure. Although Sekisui will do its best to protect your Personal Data, it cannot guarantee the security of any such Personal Data transmitted via the internet.

How long will Sekisui keep your Personal Data?

Sekisui will retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. After that time, Sekisui will delete your Personal Data from its systems and notify any third parties to whom it transferred your Personal Data of the need to delete that data. For the avoidance of doubt, the Processing period shall be the same period as the storage period.

Your rights

You have a number of rights under the PDP Law, including the right to:

• Access a copy of the Personal Data that Sekisui holds about you;
• Obtain information about handling of your Personal Data;
• Rectify inaccuracies in Personal Data that Sekisui holds about you;
• Have the Personal Data that Sekisui holds about you erased in certain circumstances;
• Restrict the Processing of your Personal Data in certain circumstances;
• Object to the Processing of your Personal Data in certain circumstances;
• Object to automated decision-making;
• Transfer the Personal Data that Sekisui holds about you to another entity in certain circumstances;
• Withdraw any consent you have provided; and
• Lodge a complaint with the relevant data protection authority.

If you would like to invoke any of those rights, please inform dp-sea@sekisui.com.

Inquiries

If you have an inquiry about the way Sekisui is using your Personal Data then initially you should contact dp-sea@sekisui.com.

Changes to Policy

We reserve the right to change, modify, add or remove portions of this Privacy Policy under PDP Law from time to time and in our sole discretion. Our policy is to alert you that changes have been made by indicating on the Privacy Policy the date it was last updated.

Last Updated: October 17, 2022samples.