Privacy Policy
                            
                            
                            
                            
                                A. INTRODUCTION
                                This Privacy Notice applies to the personal data and information managed by PT Maybank Asset Management (“Investment Manager”) as of 14 March 2025 in accordance with the terms and conditions of personal data processing applicable at the Investment Manager. 
                                
                                The Investment Manager recognizes  the importance of personal data protection  as stipulated in Law No. 27 of 2022 on Personal Data Protection, along with its implementing regulations as promulgated and amended from time to time (hereinafter referred to as the “PDP Law”), which is applicable to the Investment Manager. Therefore, the Investment Manager  is  committed  to  complying  with  the  provisions  of  the  PDP  Law  and  relevant regulations to maintain confidentiality and ensure the protection of your personal data in accordance with applicable laws and regulations. 
                                
                                For the purposes of this Privacy Notice, “Personal Data” refers to information regarding an identified  or  identifiable  individual,  either  separately  or  in  combination  with  other information, whether directly or indirectly, that can be used to identify, contact, or track the Personal Data subject through electronic or non-electronic systems as referred to in the PDP Law, its relevant regulations, and Section C of this Privacy Notice. Personal Data also includes  individual  data  contained  in  identification  cards  that  can  identify  a  person (including your photo), phone numbers, email addresses, personal financial data (including but not limited to Investment Manager account details, credit card details, and transaction data), email addresses, and date and place of birth. 
                                
                                This Privacy Notice and its amendments from time to time (the "Privacy Notice") explains how  the  Investment  Manager  processes  Personal  Data,  including  the  collection,  storage, analysis,  processing,  updating,  disclosure,  transfer,  deletion,  and/or  destruction  of  your Personal  Data  (“Personal  Data  Processing”)  through  the  use  of  Investment  Manager services/products,  websites  and/or  applications,  participation  in  certain  promotional programs  or  activities from  the Investment  Manager  and/or  third  parties  working  with  or having legal relations with the Investment Manager ("Third Parties"), both online and offline, 
                                    as well as through other activities, services, products, and features provided on the website and/or application (if any). 
                                    This Privacy Notice applies if you: 
                                    
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                                            Request information regarding the Investment Manager products. 
                                        
 
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                                            Become an Investment Manager customer; and/or 
                                        
 
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                                            Become  (i)  a  business  partner,  contractor,  and/or  supplier  of  the  Investment Manager,  and/or  (ii)  have  a  legal  relationship  with  the  Investment  Manager  for  a specific purpose, such as corporate social responsibility (CSR) initiatives. 
                                        
  
                                    
                                
                                (Hereinafter collectively referred to as "You"). You must read and fully understand this Privacy Notice to be aware of and understand how the Investment Manager processes and protects your Personal Data. 
                            
                                     
                            
                                
                                B. STATEMENTS AND WARRANTIES FROM YOU REGARDING THE PROVISION OF PERSONAL DATA 
                                
                                    You hereby declare and warrant that: 
                                    
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                                             You have read and understood all the contents of this Privacy Notice (including the Personal Data Processing performed by the Investment Manager as described in this Privacy Notice); 
                                        
 
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                                            You consent to the authenticity, completeness, and accuracy of the Personal Data you provide to the Investment Manager; and 
                                        
 
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                                            You  agree  and  understand  that  you  will  apply  the  principles  of  personal  data protection  in  accordance  with  the  PDP  Law  if,  at  any  time,  for  any  reason,  you receive Personal Data from a Third Party, including the Investment Manager. 
                                        
  
                                    
                                
                                In certain circumstances, you may be required to provide Personal Data of others (such as legally recognized spouses, family members, or other parties) to the Investment Manager. 
                                
                                If  you  provide  the  Personal  Data  of  another  person  for  processing  by  the  Investment Manager,  you  declare  and  warrant  that  you  have  lawfully  obtained  explicit consent  from that individual as the subject of the Personal Data, and you understand that the Investment Manager  relies  on  your  statement  and  warranty  in  processing  the  Personal  Data  of  the respective  individual/party.  You  are  fully  responsible  if  the  Personal  Data  you  provide, particularly that of another individual (including the personal data of a Third Party provided to  the  Investment  Manager),  is  obtained  unlawfully  or  if  your  statements  and  warranties prove  to  be  incorrect.  The  Investment  Manager  may  request  proof  of  consent  from  the respective individual whose Personal Data you have disclosed at any time if necessary.
 
                                
                                     
                            
                                C. TYPES OF PERSONAL DATA COLLECTED AND COLLECTION METHODS 
                                
                                The types of Personal Data collected depend on the purpose of Personal Data Processing. The collected Personal Data may include: 
                                    
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                                             Your  identification  data,  including  full  name,  place  and  date  of  birth,  gender, residential address, nationality, occupation, workplace address and phone number (if any), marital status, mother’s maiden name, signature, and identification card along with Personal Data contained therein (such as National Identification Number (NIK)  and/or  passport  number),  Taxpayer  Identification  Number  (NPWP  or  Tax Identification Number). 
                                        
 
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                                            Contact  data,  including  email  address,  home  phone  number,  and  mobile  phone number. 
                                        
 
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                                            Financial data, including sources of funds, average annual income and/or net worth, and the purpose of business relationships or transactions conducted by prospective customers/customers. 
                                        
 
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                                            Other personal data as stipulated by applicable laws and regulations. 
                                        
 
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                                            Third Party Data, including Third Party identification data, contact data, and other Personal Data details as mentioned above that are provided to or obtained by the Investment Manager from you. 
                                        
  
                                    
                                
                                
                                The Personal Data processed by the Investment Manager is provided directly or indirectly by you through a Third Party, including through form submissions, electronic or non-electronic document submissions, or other media. This may occur, for example, when you invest in the Investment Manager products and/or undergo a due diligence process or in other contexts necessary  to  achieve  the  purposes  of  Personal  Data  Processing  (including  from  publicly available data sources or those provided by authorized government agencies). 
                                
                                
                                     
                            
                                D. PROCESSING OF YOUR PERSONAL DATA 
                                
                                    The Investment Manager processes Personal Data as follows: 
                                    
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                                            Collection and Acquisition 
                                            
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                                                    Determining the basis for processing before collecting Personal Data; 
                                                
 
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                                                    Clearly defining the purpose of Personal Data collection with consideration of the interests of the Personal Data subject; 
                                                
 
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                                                    Limiting  the  extent  of  collected  Personal  Data  based  on  the  determined purpose; 
                                                
 
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                                                    Establishing a secure mechanism for the acquisition and collection of Personal Data; 
                                                
 
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                                                    Providing information on the purpose of processing before acquiring Personal Data; and 
                                                
 
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                                                    Applying  Personal  Data  processing  principles  as  per  applicable  laws  and regulations. 
                                                
  
                                            
                                            
                                            
                                         
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                                            Processing and Analysis 
                                            For processing and analyzing Personal Data, the Investment Manager will: 
                                            
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                                                    Establish mechanisms and/or implement data quality standards to ensure the accuracy and completeness of the processed and analyzed Personal Data. 
                                                
 
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                                                    Inform the Personal Data subject if processing and analysis extend beyond or are in addition to the original purpose. 
                                                
 
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                                                    Conduct  a  Data  Protection  Impact  Assessment  (DPIA)  for  processing  and analysis activities that pose a high potential risk to the Personal Data subject. 
                                                
 
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                                                    Facilitate the right of the Personal Data subject to object to decisions based solely on automated processing; and 
                                                
 
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                                                    Apply the principles of Personal Data processing in accordance with applicable laws and regulations. 
                                                
  
                                            
                                            
                                            
                                         
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                                            Storage 
                                            For storing Personal Data, the Investment Manager will: 
                                            
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                                                    Establish and implement security controls to safeguard Personal Data stored physically and electronically.  
                                                
 
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                                                    Establish and implement a Personal Data retention mechanism.  
                                                
 
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                                                    Determine  the  retention  period  for  Personal  Data  in  accordance  with applicable laws and regulations.  
                                                
 
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                                                    Prevent failures in Personal Data protection during storage by: 
                                                    
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                                                            Implementing encryption and/or data masking. 
                                                        
 
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                                                            Creating backup copies of Personal Data; and 
                                                        
 
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                                                            Encrypting and/or masking backup copies of Personal Data. 
                                                        
  
                                                    
                                                     
                                                 
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                                                    Restrict access to Personal Data to authorized parties only.  
                                                
 
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                                                    Identify, record, and/or document the location and media used for Personal Data storage; and  
                                                
 
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                                                    Apply the principles of Personal Data processing in accordance with applicable laws and regulations. 
                                                
  
                                            
 
                                            
                                         
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                                            Correction and Updates 
                                            For correcting and updating Personal Data, the Investment Manager will: 
                                            
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                                                    Facilitate the Personal Data subject in completing, updating, and/or correcting inaccuracies or errors in their Personal Data.  
                                                
 
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                                                    Verify  the  accuracy  of  the  Personal  Data  provided  by  the  Personal  Data subject; and 
                                                
 
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                                                    Apply the principles of Personal Data processing in accordance with applicable laws and regulations.
                                                
  
                                            
                                             
                                            
                                         
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                                             Disclosure, Transfer, Distribution, or Announcement For  displaying,  announcing,  transferring,  distributing,  or  disclosing  Personal  Data, the Investment Manager will: 
                                            
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                                                    Establish  a  legal  basis  for  processing  Personal  Data  before  displaying, announcing, transferring, distributing, or disclosing it, except where otherwise stipulated by applicable regulations. 
                                                
 
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                                                    Comply  with  the  legal  requirements  for  cross-border  transfers  of  Personal Data as outlined in applicable regulations. 
                                                
 
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                                                    Implement security controls to protect Personal Data in accordance with legal requirements. 
                                                
 
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                                                    Restrict  disclosure  of  Personal  Data  only  to  the  extent  necessary  for  the specified  processing  purpose  and  with  the  consent  of  the  Personal  Data subject, while ensuring compliance with applicable regulations; and 
                                                
 
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                                                    Apply the principles of Personal Data processing in accordance with applicable laws and regulations. 
                                                
  
                                            
 
                                            
                                         
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                                            Deletion or Destruction 
                                            For deleting or destroying Personal Data, the Investment Manager will: 
                                            
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                                                    Delete  or  destroy  Personal  Data,  except where  retention  is required  under applicable laws and regulations.  
                                                
 
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                                                    Implement  a  secure  mechanism  for  the  deletion  or  destruction  of  Personal Data.  
                                                
 
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                                                    Facilitate the Personal Data subject's right to request the deletion of their Personal Data, if it does not conflict with legal requirements.  
                                                
 
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                                                    Act  on  valid  requests  from  Personal  Data  subjects  to  delete  their  Personal Data in compliance with legal regulations by: 
                                                    
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                                                            Deleting or destroying Personal Data in accordance with legal requirements.  
                                                        
 
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                                                            Ensuring the removal of Personal Data from all storage locations. 
                                                        
 
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                                                            Retaining evidence of Personal Data deletion or destruction in the form of an official record; and 
                                                        
 
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                                                            Providing proof of deletion or destruction to the Personal Data subject; and 
                                                        
  
                                                    
                                                    
                                                 
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                                                    Apply the principles of Personal Data processing in accordance with applicable laws and regulations.  
                                                
  
                                            
                                            
                                            
                                         
                                    
                                
                                
                                     
                            
                                E. PURPOSE OF PERSONAL DATA PROCESSING 
                                
                                    Based  on  your  explicit  and  lawful  consent,  the  Investment  Manager  may  act  as  a  data controller to process your Personal Data for the following purposes: 
                                    
                                    
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                                            Provision and Processing of Selected or Owned Products, Including: 
                                            
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                                                    Providing information about the Products (including updates and modifications over  time); 
                                                
 
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                                                    Implementing  regulatory  requirements,  including  Customer  Due  Diligence (CDD),  Anti-Money  Laundering,  Counter-Terrorism  Financing,  Prevention  of Proliferation of Weapons of Mass Destruction, and Anti-Bribery and Corruption Policies related to the provision of Products; 
                                                
 
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                                                    Responding to and resolving requests related to the provision of Products; 
                                                
 
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                                                    Modifying,  enhancing,  and/or  developing  Products,  including  updates  and adjustments; and/or 
                                                
 
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                                                    Fulfilling other necessary requirements related to the provision or processing of Products for you. 
                                                
  
                                            
                                             
                                            
                                         
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                                            Execution and Enhancement of Operational Activities in Compliance with Applicable Regulations,including: 
                                            
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                                                    Performing activities related to accounting, auditing, taxation, and reconciliation associated with both the Products and the Investment Manager, as well as internal administrative processes.
                                                
 
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                                                    Fulfilling contractual obligations to you and/or third parties (including, but not limited to, vendors and partners). 
                                                
 
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                                                    Preventing,  detecting,  and  investigating  suspicious  transactions,  criminal activities, or any prohibited activities under applicable laws. 
                                                
 
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                                                    Communicating  with  you  through  various  channels,  including  responding  to inquiries, comments, or complaints. 
                                                
 
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                                                    Complying with legal enforcement requests and protecting the rights of the Investment Manager and/or yourself; and/or 
                                                
 
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                                                    Meeting other operational needs in line with business execution and regulatory compliance.  
                                                
  
                                            
                                                  
                                            
                                          
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                                            Product Offers and Promotions  
                                            The promotion of investment products, events, or other forms of marketing aligned with your needs and profile. The Investment Manager may offer products provided either directly or through third-party collaborations via various channels, including oral and written communications such as phone calls, emails, brochures, and other electronic or non-electronic media in accordance with applicable regulations (“Other Promotions”). 
                                             
                                          
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                                             The Investment Manager may process Personal Data in the event of corporate actions and/or other transactions, including but not limited to mergers, spin-offs, acquisitions,  consolidations,  restructurings,  and/or  other  activities  involving  the transfer  of  intellectual  property  rights,  insofar  as  they  involve  the  processing  of Personal Data. 
                                            
                                        
  
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                                             The Investment Manager may process Personal Data if instructed or required by an authorized  government  institution,  for  purposes  as  specified  or  regulated  under applicable laws and regulations. 
                                            
                                        
  
                                    
                                
                                     
                            
                                F. LEGAL BASIS FOR PERSONAL DATA PROCESSING 
                                
                                    Any  processing  of  Personal  Data  carried  out  by  the  Investment  Manager  is  based  on  a legitimate legal basis and is compatible with the purpose of the processing. The Investment Manager processes Personal Data based on the following legal bases: 
                                    
                                    
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                                            Your explicit and lawful consent to this Privacy Notice; 
                                        
 
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                                            Fulfillment of contractual obligations to provide Products or other necessary services as outlined in this Privacy Notice; 
                                        
 
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                                            Compliance with legal obligations under applicable regulations; 
                                        
 
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                                            Legitimate interests pursued by the Investment Manager as a data controller while ensuring a balance between the Investment Manager objectives and your rights as a Personal Data subject; and/or 
                                        
 
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                                            Any other legal grounds for Personal Data processing as required by applicable laws and regulations.  
                                        
  
                                    
                                
                                     
                            
                                G. PERSONAL DATA STORAGE, DELETION, AND SECURITY 
                                
                                    
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                                            You hereby explicitly consent that the Investment Manager may transmit, store, use, and process your Personal Data on servers located in data centers designated by the Investment  Manager.  These  data  centers  may  be  managed  by  third  parties  in compliance with applicable regulations. Notwithstanding this, the processing of your Personal Data in relation to the Products will continue to be governed by this Privacy Notice and applicable laws.  
                                        
 
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                                            Once your Personal Data is no longer required for its stated purpose, as described in this Privacy Notice, the Investment Manager will take necessary measures to delete, destroy, anonymize, and/or restrict access to or further processing of such data for any purposes other than those outlined in this Privacy Notice.  
                                        
 
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                                            Additionally,  certain  Personal  Data  may  still  be  retained  or  controlled  by  third parties,  including  government  agencies,  for  the  purposes  outlined  in  this  Privacy Notice.  If  the  Investment  Manager  discloses  your  Personal  Data  to  authorized government institutions or other entities, you acknowledge and understand that the storage and retention of such data will be subject to the policies of the respective institutions, which may override certain rights you have as a Personal Data subject under applicable regulations.  
                                        
 
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                                            The Investment Manager is committed to maintaining appropriate physical, technical,  and  procedural  safeguards  to  protect  your  Personal  Data  from  loss, misuse, unauthorized access, copying, damage, or alteration.  
                                        
 
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                                            While the Investment Manager has implemented what it considers to be the best and most  effective  measures  to  protect  your  Personal  Data—including  using  security methods and technology provided both internally and by third parties—the Investment  Manager  cannot  guarantee  absolute  security  for  transmitted  Personal Data.  However,  the  Investment  Manager  will  continue  to  make  every  effort  to safeguard and ensure the security of your Personal Data and take responsibility for the activities of third parties collaborating with the Investment Manager.  
                                        
 
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                                            If needed, you may obtain more information about the Investment Manager efforts to  protect  your  Personal  Data  by  contacting  the  Investment  Manager  through  the channels listed in Section J of this Privacy Notice. 
                                        
  
                                    
                                
                                     
                            
                                H. CROSS-BORDER PERSONAL DATA TRANSFER 
                                The  Investment  Manager  may  transfer  your  Personal  Data  outside  the  jurisdiction  of  the Republic  of  Indonesia,  and  if  required,  details  of  such  transfers  may  be  provided  upon request. 
                                
                                The Investment Manager will comply with applicable laws and regulations and make its best efforts to ensure that the level of protection provided is equivalent to that in the Republic of Indonesia and aligns with this Privacy Notice. This includes the use of standard contractual clauses for Personal Data protection related to cross-border transfers where relevant and necessary. 
                                
                                     
                            
                                I. YOUR RIGHTS AS A PERSONAL DATA SUBJECT 
                                
                                    As  a  Personal  Data  subject,  you  have  rights  as  stipulated  under  applicable  laws  and regulations concerning Personal Data protection. The Investment Manager is committed to ensuring  that  you  can  exercise  these  rights,  subject  to  the  applicable  laws  and  their limitations, which include: 
                                
                                    
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                                            The right to obtain information;  
                                        
 
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                                            The right to access and/or obtain a copy of your Personal Data;  
                                        
 
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                                            The right to complete, update, and/or rectify any errors or inaccuracies in your Personal Data;  
                                        
 
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                                            The right to terminate the processing of your Personal Data;  
                                        
 
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                                            The right to request the deletion of your Personal Data;  
                                        
 
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                                            The right to data portability, meaning the right to obtain and/or use your Personal Data  from  the  Investment  Manager  as  the  data  controller  in  a  structured  and/or standardized format;  
                                        
 
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                                            The  right  to  data  interoperability,  meaning  the  right  to  use  and  transmit  your Personal Data to another data controller;  
                                        
 
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                                            The right to withdraw consent for the processing of your Personal Data;  
                                        
 
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                                            The right to suspend  or restrict  the processing of your Personal Data in a proportionate manner; and  
                                        
 
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                                            The right to file a complaint and seek compensation in case of a violation of Personal Data  processing  due  to  the  Investment  Manager  negligence  or  errors  that  directly result in harm to you.
                                        
  
                                    
                                
                                If you would like to submit a request to exercise your rights as outlined above, you may do so through the channels or contacts provided in Section J of this Privacy Notice. 
                                
                                The Investment Manager will conduct verification and screening for all requests regarding your Personal Data rights and respond within 3 (three) business days upon receipt of your request.  To  process  your  request,  the  Investment  Manager  may  require  you  to  provide supporting  information  or  documentation  to  validate  the  request.  Once  verified,  the Investment  Manager  will  inform  you  of  any  consequences  associated with  exercising  your rights.  Upon  your  confirmation,  the  request  will  be  processed  within  the  timeframe stipulated by applicable regulations. 
                                
                                
                                    However,  under  certain  circumstances  as  regulated  by  applicable  laws,  the  Investment Manager  reserves  the  right  to  deny  your  request  to  exercise  your  Personal  Data  rights (including deletion or destruction requests) if such actions: 
                                        
                                    
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                                            Affect national defense and security interests; 
                                        
 
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                                            Affect law enforcement processes; 
                                        
 
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                                            Affect public interests in state administration; 
                                        
 
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                                            Impact financial sector supervision, financial stability, and financial system oversight in the execution of state administration; 
                                        
 
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                                            Are necessary for compliance with legal obligations, such as Customer Due Diligence (CDD) and the prevention of criminal activities; 
                                        
 
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                                            Are irrelevant to the Investment Manager Personal Data processing activities or your role as a data subject; 
                                        
 
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                                            Threaten the safety, physical, or mental health of the data subject or others; and/or 
                                        
 
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                                            Result in the disclosure of other individuals’ Personal Data.  
                                        
  
                                    
                                
                                
                                Without prejudice to legal restrictions, the Investment Manager also reserves the right to deny your request if you still have outstanding rights and obligations with the Investment Manager, its partners/agents, or third parties. 
                                
                                The  Investment  Manager  may  charge  an  administrative  fee  for  requests  related  to  your Personal Data rights, as permitted under applicable laws. 
                                
                                     
                            
                                J. INVESTMENT MANAGER CONTACT INFORMATION 
                                If  you  have  any  questions  or  complaints  regarding  this  Privacy  Notice  or  the  Investment Manager Personal Data processing activities, including requests to exercise your rights as a data  subject,  you  may  contact  PT  Maybank  Asset  Management  Customer  Service  at +622180657701 or +622180657700, or via email at id.cs@maybank.com. 
                                
                                     
                            
                                K. GOVERNING LAW 
                                This Privacy Notice is governed by the laws of the Republic of Indonesia. 
                                
                                     
                            
                                L. CHANGES OR UPDATES TO THE PRIVACY NOTICE 
                                The Investment Manager may modify, update, and/or amend this Privacy Notice from time to  time  (with  prior  notification)  to  ensure  alignment  with  the  Investment  Manager procedures and practices in Personal Data processing, as well as compliance with applicable laws and regulations. 
                                
                                You  may  access  this  Privacy  Notice  periodically  on  the  website  of  PT  Maybank  Asset Management, which is licensed and supervised by the Financial Services Authority (Otoritas Jasa Keuangan - OJK).