Privacy Notice – PT Eastspring Investments Indonesia

Last updated: June 30, 2026

Introduction

PT Eastspring Investments Indonesia (“EIID”, “we”, “us”, “our”) takes the privacy and protection of your personal data seriously.

This Privacy Notice explains how we collect, use, disclose, and process your personal data in connection with our products and services, in accordance with applicable laws and regulations, including Law No. 27 of 2022 on Personal Data Protection and relevant regulations issued by the Financial Services Authority of Indonesia (“Otoritas Jasa Keuangan” or “OJK”).

This Privacy Notice also explains your rights in relation to your personal data and how you may contact us for further information.

The role of EIID in processing personal data depends on the nature of the relationship and applicable regulatory requirements.

2. Our Role in Processing Personal Data

2.1 Where EIID acts as Data Controller

EIID acts as a Data Controller in relation to personal data of:

  • employees and job applicants.
  • directors, officers, and authorised representatives.
  • vendors, service providers, and business partners.
  • users interacting directly with EIID (including website users); and
  • customers who invest directly with EIID or grant discretionary investment mandates.

In these cases, EIID determines the purposes and means of processing personal data.

2.2 Investors via Distributors (APERD)

For investors who subscribe to funds managed by EIID through authorised distributors (Agen Penjual Efek Reksa Dana – “APERD”):

  • the distributor acts as the Data Controller for onboarding, account administration, and maintenance of investor records; and
  • EIID processes personal data only to the extent necessary to:
    1. perform its role as an investment manager. and
    2. comply with independent legal and regulatory obligations (including KYC AML/CFT, screening, monitoring, and reporting).

As investor administrative records are maintained by the distributor, any requests relating to access, correction, or updates of personal data should be directed to the relevant distributor.

3. Personal Data We Process (Part A)

Depending on the nature of the relationship, we may process the following categories of personal data:

  • identification information (e.g. name, ID card, passport, NPWP).
  • contact information (e.g. address, email, phone number).
  • financial and banking information.
  • employment or professional information.
  • investment-related information (e.g. holdings, transactions).
  • beneficiary or heir information.
  • communications and correspondence records.
  • technical data (e.g. IP address, device information, cookies); and
  • data required for regulatory compliance, including AML/CFT (Anti-Money Laundering/Counter Financing of Terrorism), and sanctions screening.

Sensitive personal data will only be processed where required by law or for legitimate regulatory purposes.

4. Where We Collect Personal Data From (Part B)

We may collect personal data from:

  • you directly (forms, applications, communications).
  • authorised distributors (APERD).
  • custodians, KSEI, and financial market infrastructure.
  • Eastspring and Prudential Group entities.
  • regulators and government authorities.
  • publicly available sources. and
  • third-party service providers supporting compliance, screening, or operations.

4.1 Cookie Policy (Part B.1)

We use cookies and similar technologies to:

  • improve website functionality.
  • understand usage patterns. and
  • enhance user experience.

You may control cookies through your browser settings.

5. How We Use Your Personal Data (Part C)

We process personal data for the following purposes:

5.1 Contractual Purposes

  • providing and managing investment products and services.
  • administering investment accounts and transactions.

5.2 Legal and Regulatory Compliance

  • KYC (“Know Your Client”) and customer due diligence.
  • AML/CFT (Anti-Money Laundering/Counter Financing of Terrorism), and sanctions screening.
  • reporting to OJK and other competent authorities.
  • compliance with applicable laws and regulations.

5.3 Legitimate Business Interests

  • risk management and fraud prevention.
  • internal administration and operational functions.
  • system improvement and service enhancement.

5.4 Based on Consent (where applicable)

  • direct marketing communications.
  • processing of sensitive personal data (where required).

6. Sharing of Personal Data (Part D)

We may share personal data with:

  • We may share personal data with:
  • regulators, authorities, and law enforcement agencies.
  • custodians, KSEI, and financial institutions.
  • authorised distributors (APERD).
  • third-party service providers (including IT, screening, and operational support).
  • professional advisors (e.g. legal, auditors).

Where personal data relates to investors subscribed via distributors, such data is primarily maintained by the distributor, and EIID’s processing is limited to what is necessary for its role as investment manager and compliance with applicable laws.

7. Cross-Border Transfers (Part E)

Personal data may be transferred outside Indonesia for operational, regulatory, or group-level purposes.

Where such transfers occur, EIID will implement appropriate safeguards and ensure compliance with applicable data protection laws.

8. Use of Sensitive Personal Data (Part F)

For certain purposes, including regulatory compliance and risk management, we may process sensitive personal data where required by law.

Where consent is required, it will be obtained at the point of collection in accordance with applicable legal requirements.

9. Retention of Personal Data (Part G)

We retain personal data only for as long as necessary to:

  • fulfil the purposes for which it was collected.
  • comply with legal and regulatory obligations; and
  • meet internal record retention policies.

10. Accuracy and Protection of Personal Data (Part H)

We take reasonable steps to:

  • ensure personal data is accurate, complete, and up to date; and
  • protect personal data through appropriate administrative, technical, and organizational measures.

You are responsible for ensuring that the information you provide is accurate and kept up to date.

11. Third-Party Websites (Part I)

Our website may contain links to third-party websites.

EIID is not responsible for the content or privacy practices of such websites. You are encouraged to review the privacy policies of those websites when accessing them.

12. Your Rights (Part J)

Subject to applicable laws, you may have the right to:

  • access your personal data.
  • request correction of inaccurate data.
  • request deletion or restriction of processing.
  • object to certain processing activities.
  • withdraw consent (where applicable).
  • request data portability. and
  • lodge a complaint with the relevant authority.

For investors whose data is maintained by distributors (APERD), such requests should generally be directed through the relevant distributor.

13. Acting on Someone Else’s Behalf (Part K)

If you provide personal data on behalf of another individual, you:

  • confirm that you are authorised to do so; and
  • confirm that you have obtained the necessary consent for such disclosure and processing.

14. Direct Marketing (Part L)

Where permitted by law and based on your consent, we may send you marketing communications relating to our products and services.

You may opt out at any time via the contact details provided below.

15. Contact Us (Part M)

If you have any questions or wish to exercise your rights, please contact:

Data Protection Officer

PT Eastspring Investments Indonesia
Prudential Tower Lantai 23
Jl. Jend. Sudirman Kav. 79
Jakarta 12910, Indonesia

Email us at:privacy.id@eastspring.com

Contact us at:

Phone: +62 21 2924 5555
Fax: +62 21 2924 5566

Or visit us:

PT. Eastspring Investments Indonesia
Prudential Tower, Lantai 23,
Jl. Jend. Sudirman Kav. 79,
Jakarta 12910, Indonesia