PT ASTRA DAIHATSU MOTOR (ADM)
PRIVACY NOTICE

I. INTRODUCTION

Welcome to the Privacy Notice of PT Astra Daihatsu Motor (ADM).
We are committed to providing Users with clear and reliable information regarding how we collect, use, and safeguard the confidentiality and security of your Personal Data. Through this Privacy Notice, we aim to ensure that you feel secure and confident that the protection of your Personal Data and privacy is our top priority.

This Privacy Notice uses the following terms with the meanings set forth below:

(i) “We” or “ADM” refers to PT Astra Daihatsu Motor, a company engaged in the manufacturing and distribution of motor vehicles in Indonesia;
(ii) “User” refers to any individual who owns Personal Data (data subject) who has used and/or will use our products and/or services, whether as a visitor or user of our website, applications, or electronic systems, as well as other third parties’ related to this Privacy Notice;
(iii) “Personal Data” refers to any data that can identify a User, either directly or indirectly, through electronic or non-electronic information, in accordance with applicable laws and regulations;
(iv) “Applicable Laws and Regulations” include all relevant regulations related to personal data protection, including Law Number 27 of 2022 on Personal Data Protection, its implementing regulations, and other applicable provisions, as well as any amendments or replacements thereto from time to time;
(v) “Processing/Management” refers to any form of action performed on Personal Data, including but not limited to the collection, recording, organization, processing, storage, adjustment, updating, dissemination, deletion, or destruction of Personal Data carried out by us.

II. APPLICABILITY

Users acknowledge that they have read, understood, and agreed to the entire contents of this Privacy Notice, and declare that they are legally authorized and entitled to provide Personal Data to ADM through the available official service channels. ADM reserves the right to amend, delete, or update this Privacy Notice as necessary, and where such changes require notification under applicable laws and regulations, we will inform Users through the Company’s official communication channels.

Users are advised to read this Privacy Notice in conjunction with the Terms and Conditions of Service, as such documents contain additional information regarding the processing/management of Personal Data in connection with the services or products provided by ADM. The version of the Privacy Notice displayed on our website, applications, or electronic systems constitutes the most recent version and supersedes all prior versions. Accordingly, Users are encouraged to review this Privacy Notice periodically for updates.

The Personal Data processed includes information provided directly by Users or obtained through interactions with ADM services or products. Such information is required to support the provision of services, the management of automotive products, or the fulfillment of legal obligations in accordance with the Company’s business activities. ADM is committed to maintaining the confidentiality of Users’ Personal Data and ensuring that all processing/management activities are conducted in compliance with applicable laws and regulations, while safeguarding privacy and information security at every stage of data management.

III. COLLECTION AND PROCESSING / MANAGEMENT OF PERSONAL DATA

COLLECTION OF PERSONAL DATA

The types of information collected may vary depending on the products or services used, the manner in which you interact with ADM, and your relationship with the Company, whether as a customer, business partner, or other related party.

The Personal Data collected by ADM includes:

1. Individual Personal Data, consisting of general personal data, such as identity information, demographic data, employment and educational background, and other information; as well as specific personal data.

2. Corporate Personal Data (for Business Partners), consisting of general corporate data, including company identity, management information, and relevant employee data; as well as specific corporate data, including company financial information, cooperation-related data, operational data, and other information.

3. Additional Data Collected Automatically

   ADM may also automatically collect certain data through digital technologies, such as device information, IP addresses, and your online activities on ADM’s websites or applications, as well as other related information.

ADM can collect your personal data in printed or electronic form as below:

1. Yourself

   Personal data can be collected from you directly through:

   a. Officers in ADM offices or plants

   b. Websites, electronic systems, official medias or events held by ADM

   c. Official representatives or appointed parties by ADM in executing operational activities

   d. Other official communication channels provided by ADM

2. Other parties

   ADM can also get your personal data through third parties based on consent that you give before to the party for giving your personal data to ADM. This personal data will be used in accordance with the purposes you have agreed to when giving your consent.

PROCESSING / MANAGEMENT OF PERSONAL DATA

ADM manages Users’ Personal Data for various purposes, including:

1. Provision and Development of Services or Products

   To provide, design, and/or develop automotive services or products, including assisting ADM in analyzing service usage, responding to user inquiries, or providing information regarding service changes.

2. Account Management and Service Access

   To manage user accounts, ensure lawful access to services or products, perform authentication, and maintain data integrity and security within ADM systems.

3. System Maintenance and Data Security

   To ensure smooth system operations, prevent unauthorized access, detect and address potential security incidents, and maintain the confidentiality and integrity of user data.

4. Internal Business Operations

   To support ADM business operations, including consultations with professional advisors such as external auditors, legal advisors, financial consultants, or other parties bound by confidentiality obligations. ADM ensures that such parties comply with personal data protection principles.

5. Regulatory Compliance

   To comply with legal requirements, including business administration, reporting to regulators, or inspections by authorized authorities, in accordance with applicable laws and regulations in Indonesia.

6. Risk Mitigation and Data Verification

   To fulfill risk management principles, including USER data verification or authentication activities in accordance with applicable legal requirements.

7. Research and Statistical Analysis

   To support research or the development of new products through statistical analysis, including the use of the latest technologies.

8. Other Purposes

   For other purposes in accordance with ADM internal policies or applicable legal provisions, adjusted to the relationship between ADM and the user.

IV. LEGAL BASIS FOR PROCESSING/MANAGEMENT OF PERSONAL DATA

The processing/management of Personal Data by ADM shall only be carried out where one or more of the following legal bases have been satisfied:

1. ADM has explicitly and lawfully obtained the User’s consent in a manner compliant with applicable personal data protection laws and regulations.

2. ADM exercises its rights and fulfills its obligations under an agreement with the User, such as a vehicle purchase agreement or other services provided by ADM.

3. ADM fulfills its obligations or requirements under applicable laws and regulations, or pursuant to orders issued by authorized authorities, including regulations related to vehicle compliance and licensing.

4. ADM processes Personal Data to protect the vital interests of the User, such as vehicle safety and the security of data related to vehicle usage.

5. ADM performs tasks carried out in the public interest and/or in the provision of public services, including compliance with transportation regulations or government programs related to the automotive industry.

6. ADM pursues other legitimate interests, while ensuring a balance between ADM interests and the rights of the User, including for purposes such as transaction data management, customer preference analysis, and the development of new products or services.

V. STORAGE OF PERSONAL DATA

ADM is committed to safeguarding and processing/managing your Personal Data with the highest level of protection in accordance with high standards, for as long as such Personal Data is required to provide the services or products we offer. The processing/management of your Personal Data will be carried out for as long as you are a customer or user of ADM services, whether as a product consumer, employee, or business partner.

After the relationship or cooperation between you and ADM has ended, your Personal Data will continue to be retained for a period of ten (10) years or longer if such retention is required under applicable laws and regulations (“Retention Period”). This Retention Period applies to all Personal Data collected during your use of our services, whether in physical or electronic form.

1. Your Personal Data may be stored in various forms and media, either at ADM facilities or at the premises of designated third parties appointed to provide data storage services, in accordance with our internal policies and applicable laws and regulations.

2. Legal retention obligations: certain types of documents are required to be retained for a longer period in order to comply with legal or regulatory obligations, such as taxation requirements or regulations applicable to the automotive industry sector.

3. Evidentiary purposes in legal proceedings: Personal Data may also be retained for a longer period where necessary for evidentiary purposes in legal proceedings, including litigation or disputes involving ADM.

Upon the expiration of the applicable storage period, ADM will delete or destroy your Personal Data from our systems in accordance with applicable regulations, so that such data can no longer be used for purposes that are inconsistent with the applicable laws and regulations.

If your Personal Data is shared with authorized government institutions or third parties that have legal obligations or cooperation arrangements with ADM, the retention of your Personal Data by such institutions or parties shall be subject to their respective data retention policies, in accordance with regulations stipulated by the relevant authorities.

VI. TRANSFER OF PERSONAL DATA

In order to support operational activities and service development, ADM may share your Personal Data within our Group of Companies and/or with third parties that cooperate with ADM or the Group of Companies (“Business Partners”), for the purposes described in the Use of Personal Data section. We may also disclose your Personal Data to supervisory institutions or relevant authorities, legal entities, or government bodies, in accordance with applicable laws and regulations in Indonesia.

For the purposes of processing/managing Personal Data as described in the Processing of Personal Data section, ADM may process your Personal Data outside Indonesia. We will ensure that the destination country of the Personal Data transfer has a level of protection that is equivalent to or higher than the level of protection applicable in Indonesia. If the destination country does not provide an adequate level of protection, we will implement appropriate and binding safeguards, such as entering into contractual arrangements with the recipient of your Personal Data and/or establishing other relevant written provisions. In such cases, ADM may continue to transfer Personal Data outside Indonesia based on your explicit consent as a User.

We are committed to ensuring that any transfer process is carried out using appropriate, reliable, and secure systems and technologies, although there may still be risks of disruption or interference by parties who are not legally entitled.

VII. PERSONAL DATA PROTECTION

ADM is committed to maintaining and protecting the security of your Personal Data obtained through our services throughout the processing/management and storage periods, in accordance with applicable laws and regulations. Therefore, we have implemented strict security procedures and utilize secure electronic systems that comply with the standards required under applicable regulations. Access to your Personal Data is restricted solely to authorized parties based on a need-to-know basis, and any party processing your Personal Data is required to do so strictly in accordance with the applicable provisions and to maintain its confidentiality.

In addition, we have a designated unit responsible for safeguarding the security of your Personal Data and conducting oversight to ensure that all security measures are implemented in compliance with our internal policies and applicable laws and regulations. ADM also continuously carries out regular monitoring and evaluation of Personal Data protection in order to anticipate potential threats to the security of your data.

When accessing ADM services or products, please ensure that you download our applications only from official channels, such as our official website, the App Store, or the Google Play Store, and do not access them through links provided by unauthorized parties. We recommend that you use only trusted platforms to minimize the risk of data leakage.

We may also require you to take the following security measures before accessing our services:

1. Entering a password or other appropriate security codes to protect your account.

2. Maintaining the confidentiality and security of access information such as usernames, passwords, and other security codes. We remind you not to disclose such information to any third party.

3. Immediately contacting us if you experience any issues related to access or your account, and following the instructions provided to restore or reactivate our services.

While we endeavor to use our best efforts to protect your Personal Data, the transmission of data, whether physically or online, may involve potential risks, particularly those relating to disruption or illegal access by unauthorized parties. We will continue to apply strict procedures and the latest security features to protect your data. In the event of a breach or illegal access to your Personal Data beyond ADM’s control, we will notify you within a reasonable timeframe so that you may take the necessary steps to mitigate any potential impact or risks that may arise.

VIII. USER RIGHTS

In accordance with applicable laws and regulations and ADM internal policies, your rights as a Personal Data Subject include the following:

1. Right to Get Information

   You have the right to obtain clear information regarding our identity as the data controller, the legal basis for the processing/management of data, and the purposes for the collection and use of your Personal Data. Such information will be provided in an appropriate structure or format that is commonly used and can be easily read by existing electronic systems. This is intended to ensure that you receive transparent understanding on how your Personal Data is used and protected in support of ADM business activities.

2. Right to Update Personal Data

   You have the right to request that the Personal Data we hold be completed, updated, or corrected if it is inaccurate or incomplete. Therefore, you may submit a request along with detailed information and supporting documents relating to the relevant data. We will endeavor to ensure that the Personal Data we store remains accurate and relevant in order to support our business objectives i.e. to provide the best possible services to customers and business partners.

3. Right to Access Personal Data

   You have the right to access and obtain a copy of your Personal Data we hold. Such requests will be processed in accordance with applicable procedures, which generally require a written request from you. The provision of copies may be subject to fees in accordance with ADM policies, and we will ensure that you are provided with reasonable access to such information in support of a transparent business relationship.

4. Right to Delete Personal Data

   You have the right to request the cessation of processing/management, deletion, and/or destruction of your Personal Data, particularly if such data is no longer necessary for the stated purposes or there is no other legal basis for its processing/management. Your request will be considered in accordance with the deletion criteria established by ADM and applicable laws and regulations. Please note that following the deletion of Personal Data, you may no longer be able to use some or all of our services related to the automotive products and services we offer.

5. Right to Withdraw Consent

   If the processing/management of your Personal Data is based on consent provided through consent mechanisms such as ticking a checkbox or other means, you have the right to withdraw such consent at any time. The withdrawal of consent will be binding upon us and will be respected once it becomes effective. Please note that withdrawing consent may affect the services or products we provide to you, particularly where such processing/management is required for the provision of certain services, such as after-sales services or vehicle products that rely on your Personal Data.

6. Right to Restrict or Object to the Processing/Management of Personal Data

   You also have the right to delay or restrict the processing/management of your Personal Data, particularly if such processing/management is no longer relevant to the stated purposes or you think that such processing/management does not comply with applicable provisions. Any restriction may be exercised by submitting clear and written restriction information to ADM. We will consider such requests; however, please note that in certain cases, such restrictions may affect the quality of services we are able to provide, as the processing/management of Personal Data is an integral part of the provision of certain services, such as customer support and automotive product innovation.

IX. PROVISION OF PERSONAL DATA AND ACTING ON BEHALF OF OTHERS

Users are obligated to provide accurate data, information, and/or Personal Data to ADM. Failure to provide the required data or information may result in ADM being unable to provide services maximally to the User.

If a User provides the Personal Data of another individual (such as family members, business partners, or other related parties), the User represents and warrants that he or she has obtained the necessary consent and authority from such individual to provide their Personal Data and/or to act on their behalf. The User further confirms and warrants that such individual has been informed of the collection and processing/management of their Personal Data and has consented that their Personal Data being further processed in accordance with applicable laws and regulations.

If the Personal Data provided includes information relating to a minor, the User acting on behalf of such minor represents and warrants that he or she has obtained consent from the minor’s parent or lawful guardian to provide the Personal Data and to consent to the processing/management of such data in accordance with applicable provisions. Parents or lawful guardians have the right to contact us to request the deletion of a minor’s Personal Data that has been provided without their consent.

CONTACT US
For general inquiries, please contact ADM User Services through:
Telephone: 6510300

For requests related to personal data protection, including a minor’s personal data, please contact:
Email: DPO@daihatsu.astra.co.id