Terms of Use and Information Policy

Important:

This policy was last updated on 5 September 2024. You are encouraged to visit this page or this policy to ensure you are informed of our updated Personal Data Policy.

PT FWD Insurance Indonesia (hereafter referred to as “FWD Insurance” or “We”) is committed to protect and respect your right to protection of the Personal Data entrusted to Us and ensures that the acquisition, collection, use, processing, analysis, storage, rectification, updating, display, transfer, disclosure, erasure and/or destruction (hereafter referred to as “Processing”) of your Personal Data will be carried out in accordance with the provisions of laws and regulations and other applicable guidelines.

For the purposes of this Personal Data Policy, when you interact with FWD Insurance, provide and/or submit your Personal Data information to FWD Insurance when using/visiting FWD Insurance's websites and/or other applications, enquire or register for any products, campaigns, promotions or activities offered by FWD Insurance, you are a data subject who’s subject and agree to this Personal Data Policy and hereafter referred to as “You”.

When We refer “Personal Data”, We refer to an identified or identifiable natural person data individually or in combination with other information either directly or indirectly through electronic or non-electronic systems as set out in Law No. 27 of 2022 on the Protection of Personal Data (hereafter referred to as “UUPDP”). We perform Processing of your Personal Data in order to provide the products and/or services you have requested or to comply with legal or contractual requirements.

This Personal Data Policy provides You with information on how and why We carry out the Processing of Your Personal Data, to whom and where it is shared and transferred to, how long We retain Your Personal Data, Your rights as a subject of Personal Data, what steps We can take to ensure the security of Your Personal Data so that it remains protected from unauthorized access, unauthorized disclosure, unauthorized alteration, misuse, destruction and/or erasure of Personal Data, Our policy on direct marketing and the use of cookies and/or how You can contact Us. The provision of Your Personal Data is legal and voluntary, and You may choose not to provide Us with the requested Personal Data, but failure to do so may result in Us being unable to provide and/or deliver Our products and/or services to You including may result in the cancellation of Your policy. Please read this Personal Data Policy to further understand the Processing and protection of Personal Data that applies to FWD Insurance including knowing your rights over the Personal Data that you have provided to Us.

1. FWD Insurance may collect and/or obtain your Personal Data of a general and/or specific nature (as defined under the UUPDP and/or other applicable relevant laws and regulations):
   1. identity-related information such as full name, gender, nationality, religion, marital status, email address, telephone number, card or bank details (for the chosen payment method);
   2. professional information such as profession, occupation, company name and domicile address, business email address, office telephone number;
   3. technical information such as IP address, browser information, operating system and platform, device information;
   4. health data and information, biometric data, genetic data, criminal records, child data, your personal financial data, and/or other data in accordance with the provisions of the UUPDP and/or other applicable laws and regulations;
   5. you may also be asked to provide some information and Personal Data about your insured, beneficiaries, heirs, beneficial owners and/or others. By providing and/or submitting their Personal Data information, You confirm and warrant that You have obtained their written consent validly, not misleadingly and in accordance with the provisions in the applicable laws and regulations and release FWD Insurance from all legal consequences, claims and/or lawsuits of any kind and from any person arising from and/or in connection with Our Processing of their Personal Data.
      
      
2. Children's Personal Data
   Any Personal Data of children for which Processing is carried out by FWD Insurance has obtained the consent of the child's parents and/or guardians in accordance with the provisions in the UUPDP and/or other applicable laws and regulations.
   
   
3. The above Personal Data may be collected, obtained, and stored by FWD Insurance by:
   1. directly when You fill in an application or request form provided by Us, deal with Us over the telephone, send Us a letter or use Our websites, social media platforms, electronic media or applications to submit queries, requests and/or other communications;

   2. indirectly through Our distribution partners and marketers/agents who meet with You to discuss and offer FWD Insurance products and services, organizations or third parties with whom We have agreements including but not limited to third parties who at the time of Personal Data collection have obtained consent from You to provide Your Personal Data to Us; and/or

   3. from publicly available sources of information and/or from other parties such as: other insurers, reinsurers, distribution partners, governments, legal entities, any medical information sharing facilities, regulators and/or law enforcement agencies that have obtained consent from You to provide Your Personal Data to Us. 
      
      

4. The purposes for which FWD Insurance processes your Personal Data and how We use it
   The purposes for which Your Personal Data is collected may be used and/or processed for a variety of customized purposes depending on the circumstances or situations that require Us to use or process Personal Data, among others, generally for the design, development and/or provision of FWD Insurance products and services as a whole and in accordance with applicable laws and regulations, maintaining and managing Your account and conducting data analysis, data matching and/or research conducted by FWD Insurance and/or other institutions and/or other purposes notified by Us and/or Our representatives including Our agents and/or marketers explicitly from time to time.
   
   
5. Who can or may your Personal Data be disclosed to?
   Personal Data will be kept confidential, but where permitted under the UUPDP and/or other applicable laws and regulations or where such disclosure is necessary to fulfil a purpose or purposes directly related to the collection of Personal Data, FWD Insurance may provide, disclose and/or transfer your Personal Data to other parties, both within and outside the jurisdiction of Indonesia for the purposes referred to in number 4 above or other purposes to which you have consented, including the following:

   1. any person authorized to act as a marketer/agent of FWD Insurance in connection with the marketing of Our (or such FWD Group company's) products and services;

   2. any agents, contractors and/or third party service providers (within or outside FWD Insurance and/or the FWD Group) who provide administrative, data processing, telecommunications, computer, payment, printing, exchange, debt collection or securities clearing, technology outsourcing, mailing and printing services, call center services and/or other services in connection with the business operations and provision of FWD Insurance services to You;

   3. any member company of the FWD Group in connection with the provision and/or marketing of insurance services;

   4. any agents, contractors and/or third party service providers including companies that help deliver Our services, such as reinsurance companies, investment management companies, claims investigation companies, couriers, industry associations and/or federations, partnerships;

   5. other companies that help collect Your information or communicate with You, such as research companies and rating agencies, to improve the services We provide to You;

   6. doctors, hospitals, health centers, clinics, medical personnel, laboratories, loss assessors, risk intelligence providers, insurance claims investigation service providers, administrators, and/or other professional advisors engaged by FWD Insurance;

   7. administrators, and/or other professional advisors engaged by FWD Insurance; any of our professional advisors including attorneys, public accountants and auditors; and/or

   8. any government or regulator in any jurisdiction or any person to whom FWD Insurance or any FWD Group member company is required to disclose data: (i) pursuant to legal and/or regulatory obligations applicable in the relevant jurisdiction or any other jurisdiction applicable to FWD Insurance or such FWD Group member company; or (ii) pursuant to commitments entered into between FWD Insurance or a FWD Group member company and the relevant government, regulator, agency and/or other natural person in order to operate the business activities of FWD Insurance or a FWD Group member company.
      
      

6. How long do We keep Your Personal Data?
   FWD Insurance may retain Your Personal Data for as long as necessary and We will comply with all requirements in the UUPDP and/or other applicable laws and regulations in Indonesia. FWD Insurance will implement reasonable security measures based on the provisions set out in the UUPDP and/or other applicable laws and regulations to prevent the unauthorized or accidental access, acquisition, collection, processing, analysis, storage, rectification, updating, display, announcement, transfer, dissemination, disclosure, deletion, destruction, erasure and/or use of Personal Data including restricting physical access to data in FWD Insurance's systems and encryption of sensitive data when transferring such data. Such reasonable steps will be taken to delete or destroy information when it is no longer required for any of the above purposes.
   
   
7. Right of Access to Personal Data under the UUPDP and/or other applicable laws and regulations, you have the right to:
   1. verify whether FWD Insurance holds Personal Data about you, obtain information about the clarity of identity, the basis of legal interests, the purpose of the request and use of Personal Data and the accountability of FWD Insurance;
   2. request to FWD Insurance to complete, update and/or correct any errors and/or inaccuracies in the Personal Data about you in accordance with the purposes of the Personal Data Processing;
   3. access data and/or information about how FWD Insurance uses and/or discloses your Personal Data;
   4. apply for, gain access to, obtain and/or use a copy of your Personal Data from FWD Insurance in a structured format and/or a format commonly used or readable by electronic systems and in this regard FWD Insurance reserves the right to charge fees related to providing copies of Personal Data;
   5. apply for termination of Processing, erasure and/or destruction of Personal Data concerning you in certain circumstances in accordance with the provisions of the UUPDP and/or other applicable laws and regulations;
   6. withdraw consent to the Processing of your Personal Data or request changes to the scope of your consent;
   7. delay or restrict FWD Insurance's means in the event that the Processing of Personal Data is incompatible with the purposes of the Processing of Personal Data and/or object to automated Processing decision-making actions for the Processing of Personal Data and/or profiling, which give rise to legal consequences or have a significant impact on you; and/or
   8. complain and/or report if there is a violation of the protection of Personal Data in the Processing of Personal Data carried out by FWD Insurance.
Access requests, corrections, complaints and/or other queries relating to your Personal Data can be made to FWD Customer Care at 1500 525, the toll-free Hotline at 0800 1500 525 or by email to CustomerCare.id@fwd.com.


8. What measures we have implemented to protect your Personal Data?
   In providing Personal Data protection, FWD Insurance has in place or appointed officers or officials who carry out Personal Data protection functions including implementing reasonable security measures to protect your Personal Data from unauthorized or accidental access and/or Processing of Personal Data. Measures have been taken to ensure the integrity, prudence and competence of persons having access to your Personal Data and that such Personal Data is processed in a secure manner and in accordance with the provisions of the UUPDP and/or other applicable laws and regulations.
   
   
9. Direct Marketing
   In addition to the purposes mentioned above, where permitted under the UUPDP or other applicable laws, We may use Your name, contact details, services and product portfolio information, financial background, and demographic data for promotional or marketing purposes and conduct direct marketing to market products and services that may be relevant to You. If you do not want Us to use your Personal Data for direct marketing purposes, you can provide notice to Us by contacting FWD Customer Care on 1500 525, the toll-free Hotline on 0800 1500 525, or email to CustomerCare.id@fwd.com.
   
   
10. Hyperlinks and Cookies
    The FWD Insurance website may include hyperlinks to third party websites. FWD Insurance has no control over the content, accuracy, opinions expressed and links provided on third party websites or how they handle your Personal Data. You are encouraged to visit third party websites for details regarding their privacy policies in handling your Personal Data. 

    FWD Insurance may use cookies to improve Our internet services. Cookies are small files of letters and numbers that are automatically stored on your computer's browser and can be viewed by the FWD Insurance website. Cookies can help Our website to recognize you and your list of favourites or general usage when you visit the website, as well as helping FWD Insurance to customize the website to suit your needs.

    The data collected by cookies is anonymous data customization. Therefore, there is no data regarding your name, address or any data that allows the other party to contact you by phone, email and other forms of contact. None of your Personal Data is stored in cookies. However, you may block the use of cookies by adjusting your browser settings. Blocking cookies may impact your use of Our website or online services, such as difficulty transacting through the FWD Insurance website and a longer time to request additional data.
    
    

11. Updates to this Personal Data Policy
    As part of Our efforts to ensure that We properly manage, protect and conduct the Processing of Your Personal Data in accordance with the provisions of the UUPDP and/or other applicable laws and regulations, We may, at Our discretion, from time to time update this Personal Data Policy by notice to You via this page. Last updated on 5 September 2024.