A. Privacy Statement

PT Sunindo Kookmin Best Finance ('SKBF') is committed to protecting and safeguarding information or data about individuals that are identified or identifiable separately or in combination with other information either directly or indirectly through electronic or non-electronic systems ('Personal Data') of Clients, Partners, or other related parties, by implementing the best privacy protection standards and strategies in accordance with Law No. 27 of the Year 2022 on Personal Data Protection ('PDP Law'), its implementing regulations, and other relevant laws and regulations.

This Privacy Policy helps you understand how we process your Personal Data ('Privacy Policy') while keeping in mind the principles of processing Personal Data in accordance with applicable regulations. This policy applies to all Personal Data obtained and processed by SKBF, either directly from you or from third parties who cooperate with us ('Third Parties') in the context of providing services, solutions, or technology products and integration systems.

This policy also applies to users who visit websites, applications, or other electronic channels managed by SKBF. This Privacy Policy does not apply to third-party electronic services or channels that are not managed by us.

B. Principles of Personal Data Protection at SKBF

As a Personal Data Processor in accordance with the PDP Law, SKBF applies the following principles:

1. The processing is carried out lawfully, transparently, and according to the purpose that has been determined.
2. Respect and guarantee the rights of the Personal Data Subject.
3. Ensure data is accurate, up-to-date, and accountable.
4. Protect the security of Personal Data from unauthorized access, disclosure, alteration, misuse, or destruction.
5. Notify the purposes and activities of the processing, including in the event of a personal data protection breach.
6. Delete or destroy data after the retention period has ended, unless otherwise specified by laws and regulations.

C. Privacy Policy Updates

SKBF may update this Privacy Policy at any time. Changes will be announced through official media or communication channels, and the latest version will replace the previous version.

In the event of an update to the Privacy Policy, the Personal Data protection policy used is as stated in the most recent Privacy Policy, and the previous version of the Privacy Policy is declared invalid.

D. Purposes of Personal Data Processing

SKBF processes Personal Data about the Personal Data Subject in accordance with the PDP Law and/or its related implementing regulations. The processing of Personal Data carried out by SKBF includes the acquisition and collection, processing and analysis, storage, correction and updating, display, announcement, transfer, dissemination, or disclosure, and/or deletion or destruction of Personal Data ('Processing').

In general, the Processing of Personal Data by SKBF is carried out for purposes that include ('Purposes of Processing'):

1. Provision of integrated system services and solutions, including installation, configuration, testing, maintenance, and technical support.
2. Implementation of business operational activities and commercial relations with clients or partners.
3. Performance of a contract or agreement.
4. Employee relationship management and recruitment process.
5. Comply with applicable legal and regulatory obligations.
6. Service development, system security improvement, and technological innovation.
7. Non-commercial activities such as corporate social responsibility (CSR).

E. Types and Relevance of Personal Data

SKBF processes Personal Data, both general and specific, for each Processing Purpose, taking into account the principles of Personal Data protection in accordance with the PDP Law.

The Personal Data processed includes:

1. Name, telephone number, email address, residential address, correspondence address, place and date of birth.
2. Gender, religion, signature, photo, nationality, occupation, marital status, educational background information.
3. Valid identity card information, including but not limited to ID card, passport, KITAS and/or KITAP.
4. Tax or immigration information such as Tax Identification Number (TIN), and data on migration documents.
5. Information about individuals associated with the Personal Data Subject, including but not limited to family, partners, and associates.
6. Information on health insurance cards and employment security cards in accordance with laws and regulations.
7. SKCK information, vehicle license and/or equivalent
8. Financial information, payments, income, banking, financial transactions.
9. Health information, medical history, and health risks.
10. Information about cookies and visit records on website pages and/or other electronic systems managed by SKBF.
11. Information about property, assets, and/or other evidence and/or deeds of ownership related to the Personal Data Subject
12. Information about criminal records and offenses.
13. Biometric data, including but not limited to face recognition, fingerprints.
14. Digital activity information, including but not limited to geolocation, IP address, Personal Data Subject activities on SKBF's online channels
15. Information about other Personal Data that is reasonably necessary in connection with the provision of the Company's services and/or products to the Personal Data Subject.

F. Legal Basis for Personal Data Processing

For each Personal Data Processing Purpose, SKBF processes Personal Data by establishing the following processing basics:

1. Explicit valid consent of the Personal Data Subject.

   In connection with the implementation of non-commercial activities and the marketing of the Company's services and/or products, SKBF may process Personal Data based on the consent of the Personal Data Subject. If SKBF uses the legal basis for consent, the Personal Data Subject may withdraw his/her consent at any time.

2. Fulfillment of treaty obligations.

   SKBF may enter into an agreement with the Personal Data Subject to fulfill the obligations of the agreement between SKBF and the Personal Data Subject or to fulfill the Personal Data Subject's request. In connection with this, if the processing of Personal Data is required by SKBF in the context of fulfilling the obligations of the previously agreed agreement, then SKBF may use this basis of processing.

3. Fulfillment of SKBF's legal obligations in accordance with laws and regulations.

   SKBF processes Personal Data in connection with the fulfillment of the Company's legal obligations ordered in accordance with applicable laws and regulations, including but not limited to responding to court orders, legal process, and/or obligations based on the authority of any government body, in accordance with laws and regulations.

4. Fulfillment of the protection of the vital interests of the Personal Data Subject.

   In certain emergencies that threaten the life, body, physical, assets and/or property of the Personal Data Subject, SKBF may process Personal Data on the basis of fulfilling the protection of vital interests as the Personal Data Subject.

5. Fulfillment of other legitimate interests with due regard to the objectives, needs, and balance of interests of SKBF and the Personal Data Subject.

   SKBF has a legitimate business and commercial interest to process the Personal Data of the Personal Data Subject in connection with the effective improvement of services and the effective implementation of the Company's operational activities.

G. Rights of Personal Data Subjects

The Personal Data Subject has the right to Personal Data in accordance with the PDP Law, other laws and regulations, and internal policies set by the SKBF by taking into account the legal basis for processing Personal Data, including provisions on exceptions in accordance with laws and regulations. The rights of the Personal Data Subject in question include ('Data Subject Rights').

1. The right to obtain Information about the clarity of identity, the basis of legal interests, the purpose of the request and use of the Personal Data, and the accountability of the party requesting the Personal Data.
2. The right to complete, update, and/or correct errors and/or inaccuracies in Personal Data in accordance with the Purposes of Personal Data Processing.
3. The right to access and obtain a copy of Personal Data about the Personal Data Subject in accordance with the provisions of the law.
4. The right to terminate the processing, deletion, and/or destruction of Personal Data in accordance with the applicable laws and regulations.
5. The right to withdraw consent to the processing of Personal Data.
6. The right to object to decision-making actions that are based solely on automated processing, including profiling, in accordance with applicable laws and regulations.
7. The right to suspend or restrict the processing of Personal Data proportionately in accordance with the Purposes of the Personal Data Processing.
8. The right to sue and receive compensation for the violation of the processing of Personal Data in accordance with applicable laws and regulations and/or
9. The right to data portability.

Requests for delay or restriction, termination, and/or withdrawal of consent to the processing of Personal Data and/or deletion and/or destruction of Personal Data by the Personal Data Subject may affect SKBF's ability to provide products, services, and services to the Personal Data Subject, including may result in the termination of SKBF's services to the Personal Data Subject.

To ensure that the implementation of Personal Data Subject Rights is carried out effectively and in accordance with laws and regulations, SKBF may establish policies on the mechanism and procedure for applying for Personal Data Subject Rights. The Personal Data Subject may apply through the following contacts:

Email: dpo@skbf.co.id

SKBF reserves the right to reject the application for rights submitted by the Personal Data Subject for the reasons that have been determined in accordance with the PDP Law and other relevant laws and regulations.

H. Period of Processing, Storage and Retention of Personal Data

SKBF may process Personal Data for as long as necessary and proportionate to achieve the Processing Purposes. In connection with the implementation of the Processing Purposes, SKBF stores Personal Data responsibly, paying attention to the security and confidentiality of Personal Data, both non-electronic and electronic.

Personal Data that is no longer necessary to achieve the Processing Purposes will be stored for the retention period regulated in accordance with laws and regulations.

Personal Data processed by SKBF will be deleted if the retention period has passed and/or there is a request for deletion and/or destruction by the Personal Data Subject. In the event that SKBF cooperates with the Personal Data Processor, SKBF ensures that the Personal Data is deleted and/or destroyed by the Personal Data Processor. SKBF may retain Personal Data for longer than the specified time limit if it is necessary for legal purposes, help detect financial crime, respond to requests from regulators or authorized authorities, and other matters.

I. Automated Processing-Based Decision-Making

SKBF may process Personal Data based on automated processing tools, including but not limited to profiling activities. In connection with the processing of Personal Data by automated processing tools, the Personal Data Subject may object to SKBF's decision-making activities which are based solely on automated processing.

J. Transfer and Disclosure of Personal Data

SKBF may transfer and/or disclose Personal Data about Personal Data Subjects to Personal Data Processors, other Personal Data Controllers, and/or other Third Parties who cooperate with SKBF to achieve the Processing Purposes that have been set, including the transfer and/or disclosure of Personal Data to Other Countries, in accordance with the PDP Law and its related implementing regulations.

K. Personal Data Security Measures

For each Personal Data processing activity, SKBF implements technical and organizational measures in accordance with laws and regulations and the Company's policies to ensure the security and confidentiality of Personal Data.

L. Marketing Activities

If the Personal Data Subject has given consent to his/her Personal Data to be processed by SKBF for marketing purposes, SKBF will process the Personal Data in accordance with marketing purposes, including but not limited to, service and/or product promotions, information on the implementation of non-commercial activities, and other relevant marketing activities in accordance with laws and regulations.

The Personal Data Subject may request not to receive promotional and/or marketing materials from SKBF In connection with this, SKBF will cease and/or not process the Personal Data of the Personal Data Subject for marketing purposes. Requests for withdrawal of consent and/or termination of marketing can be made through the following contact persons:

Contact: dpo@skbf.co.id

M. Contact the Personal Data Protection Officer

The Personal Data Subject may send questions, complaints, confirmations, or other related to how SKBF processes and/or protects Personal Data by sending an email to the address: dpo@skbf.co.id.

Publish Date
14/11/2025