PT Perdana Wahana Sentosa (“PWS“) is an insurance brokerage company that has been licensed at Otoritas Jasa Keuangan ("OJK") as an insurance broker with a Licensed Certificate from OJK No.KEP-341/KM.10/2011 dated 18 April 2011 so that implementation of strict monitoring activities by OJK based on Peraturan Otoritas Jasa Keuangan Nomor 70/POJK.05/2016 (“POJK 70”) concern with the Business Conduct of Insurance Brokerage Companies, Reinsurance Brokerage Companies, and Insurance Loss Appraisal Companies.

Special Provisions

"Personal Data" is all data, description, information and documents of the User and/or parties related to the User (family, colleagues, employees, companies or service providers for the User and/or other related parties) which are stored, maintained and guarded including data, related information and documents or their derivatives which:

1. Required or obtained by PWS from Users or submitted, disclosed, downloaded or submitted by Users through the PWS platform or PWS resources;

2. Legally obtained or accessed by PWS based on PWS internal policies and procedures regarding PWS Services as long as The User is still bound by Collection and Use of Personal Data (PPDP) this; and/or;

3. Constitutes data or information that must be submitted and/or has been provided by User as an obligation according to the terms of the agreement or voluntarily from time to time with due observance of existing laws and regulations.

Objective

PWS has the right to request, obtain, collect, process, store and use Personal Data of Users in the framework of or related to efforts or purposes of:

1. Assessment, analysis, verification, implementing Know Your Customer Principles, validating or examining:

   1. Insurance application or application;

   2. Process or application for registration as an insurance beneficiary;

   3. User's profile;

2. Fulfillment of PWS rights and obligations based on legal provisions and statutory regulations, agreements;

3. Implementation and supervision of the implementation of the Agreement;

4. Implementation of PWS business and operational activities from time to time;

5. Survey, research, evaluation and/or product or service development by PWS or other interested parties; and/or

6. Implementation of PWS Standard Operating Procedures (SOP) while taking into account the general provisions in the Policy Guidelines and Purpose of Security Control so that they can still recommend a series of security controls that are specific and safe.

7. Law enforcement and PWS compliance with the provisions of law and laws and regulations.

The purposes above are a stipulation that becomes the legal basis for PWS to store, process and use User Personal Data even though the User is no longer bound by this PPDP, and to use it, submit it or disclose it with the aim and good faith to:

1. Bank and non-bank financial institutions, credit scoring bureaus, collection agencies and/or other interested third party service providers as long as this matter is bound by a confidentiality responsibility for User's Personal Data;

2. Representative, any party related to or part of PWS and is responsible for the confidentiality of the User's Personal Data for a particular purpose; and/or

3. Financial Services Authority, courts, prosecutors, police, other government institutions either at the initiative of PWS or as required by legal provisions and regulations, directives, instructions or policies of government institutions or government officials.

Methods of Obtaining, Collection and Storage of Personal Data

1. PWS has the right to obtain, collect and store Personal Data from and/or through the PWS Platform, telephone, short messages, obtained from PWS tools, systems or resources, affiliates or related parties or representatives of PWS, or which is accessed by PWS and/or submitted by User through and/or obtained from systems, hardware (hardware), software (software) or equipment (devices) that PWS or Users use or are involved in utilizing and using PWS Services and/or PWS Platforms.

2. Storage of Personal Data by PWS is for a minimum of 5 (five) years in accordance with the provisions of 15 paragraph (3) of the Minister of Communication and Information Regulation Number 20 of 2016 concerning Protection of Personal Data in Electronic Systems. PWS will carry out this storage in accordance with the Implementation of Standard Operating Procedures (SOP) of PWS with due observance of the general provisions in the Policy Guidelines and Security Control Objectives, either through the PWS system or other party systems, servers or databases or other third party service providers in the region Republic of Indonesia (“Appointment of Third Parties for Storage of Personal Data”).

Limitations and Remedies

PWS is fully committed not to trade User Personal Data to any party, including making reasonable efforts that each of its employees is not involved in the sale and purchase of User's Personal Data to any party.

PWS is not responsible for any loss in any form or risk of loss experienced by User or User or any party resulting from or related to the Personal Data including failure to protect the confidentiality of Personal Data, submission, access, acquisition, processing, storage or use or transfer thereof, including but not limited to disputes, investigations, audits, law enforcement and any investigative process, which are not proven to be caused, neglected or involving PWS or PWS employees, representatives, proxies, affiliates or other related parties ("Losses and Legal Issues").

For clarity, legal certainty and transparency:

1. PWS is hereby released from all forms of compensation, obligation to respond and cannot be involved, including its employees, subsidiaries, affiliates or representatives, for any claims, demands, requests or statements whatsoever arising from and/or related to Losses and Legal Issues that submitted without including an exact calculation that has been quantified, accurate and accountable for the real and direct damage that the User has experienced, along with evidence that can be accepted by the court or the relevant judicial institution regarding PWS errors or omissions based on Articles 1865 and 1866 of the Book Civil Law Act, Article 164 Het Herziene Indonesisch Reglement and Article 5 paragraph 1 Law Number 11 of 2008 concerning Information and Electronic Transactions;

2. PWS is hereby released from all forms of responsibility for accuracy and accuracy (except for Personal Data that has been verified by PWS in accordance with its Standard Operating Procedures (SOP) and Policy Guidelines), validity, legality and completeness of Personal Data User and is not required to notify User or other parties any of these matters unless legally required; and/or;

3. PWS is not responsible for violations of the law User or any third party rights resulting from or related to obtaining or providing Personal Data. In the event that there is an Appointment of a Third Party for Storage of Personal Data, then User hereby releases PWS or PWS employees, attorneys, representatives, affiliates or related parties in the event of a breach of confidentiality or failure of confidential protection of Personal Data or Losses and Legal Issues involving, caused or carried out by third parties who hold the Personal Data concerned from all forms of claims both material and immaterial by the User. However, PWS will still make reasonable efforts to notify you of such breaches of confidentiality when PWS finds out about it from the third party.

User Rights To Change, Add or Update Personal Data

To ensure the accuracy and updating of User's Personal Data, Users can submit a written request via e-mail to PWS for the purpose of changing, adding or updating Personal Data previously obtained or submitted to PWS and each such request must be sent to PWS e-mail at help@prodiginow.com or support@prodiginow.com to be followed up by PWS.

User Right to Determine Confidential and Non-Confidential Classification of Personal Data

Users can submit a written notification via e-mail to PWS for the purpose of determining which information, data or documents are confidential from or related to the Personal Data, to be followed up by PWS by seeking to protect the confidentiality of the part of the Personal Data that is classified as confidential. The written notification as referred to above must be sent to the PWS e-mail at help@prodiginow.com or support@prodiginow.com so that PWS can follow up.