A. DEFINITIONS

Unless otherwise defined in this Privacy and Personal Data Protection Policy, all capitalized terms used in this Privacy and Personal Data Protection Policy shall have the following meanings:

1. “Affiliate” means any company or other entity that directly or indirectly controls, is controlled by, or is under common control with TELKOM.
2. “You” refers to You as a user, potential user, and/or paying user of OCA services.
3. “Anonymous Data” means data and information, including Your Personal Data, that no longer contains any information identifiable to You, as the data containing Your identification has been removed from it or the data and information have been merged with other data and information, making them unidentifiable to You either as an individual or as an entity.
4. “Personal Data” means data about an individual that can be identified or is identifiable, either independently or in combination with other information, both directly and indirectly through electronic or non-electronic systems, which, in this case, are systems owned by TELKOM. TELKOM categorizes Personal Data into Specific/Sensitive Personal Data and General Personal Data.
5. “End User Personal Data” refers to any data belonging to Your End Users, which may take the form of General Personal Data or Specific/Sensitive Personal Data.
6. “Specific/Sensitive Personal Data” refers to sensitive Personal Data that requires specific and heightened protection compared to other Personal Data in accordance with applicable laws and regulations, including but not limited to bank account details, credit/debit card numbers, personal financial information, child-related Personal Data, biometric data, criminal records, and transaction data containing Personal Data.
7. “General Personal Data” refers to general Personal Data that does not fall under the category of Specific/Sensitive Personal Data, including but not limited to; full name, mother’s maiden name, gender, address, place and date of birth, phone number, email address, occupation, IP address, geo-location data, unique device identifiers, photographs, identity card numbers issued by authorized authorities (such as but not limited to; National ID (KTP), Driver’s License (SIM), or passport), citizenship, signature, and profile information.
8. “End User” refers to any person or company who purchases or uses the products or services offered by You and enters into a direct or indirect agreement with You.
9. “TELKOM Contact” refers to the means by which You can contact TELKOM for the implementation of this Privacy and Personal Data Protection Policy.
10. OCA services refer to the services provided by TELKOM that allow You to use various OCA products, including but not limited to OCA Blast, OCA Interaction, OCA WhatsApp Business API, and OCA AI, which are accessible on the OCA Page.
11. OCA (Omni Communication Assistant) is a web-based application managed by PT Telekomunikasi Indonesia Tbk (‘TELKOM’) that provides services for broadcasting messages in written or audio form, as well as other services that may be developed over time.
12. “Authorized Authority” refers to any institution or agency with authority under applicable laws and regulations, including but not limited to; ministries, non-departmental institutions, courts, and law enforcement agencies.
13. “Processing” or “Process,” depending on the context and sentence structure, refers to the activities of acquiring and collecting, processing and analyzing, storing, disclosing, deleting, and/or destroying Personal Data and/or other information.
14. “Destruction” refers to the activity aimed at completely or partially erasing Your Personal Data from TELKOM’s electronic and non-electronic systems so that it cannot be accessed in the future.
15. “Deletion” refers to the activity aimed at limiting the use of Your Personal Data and/or Your End Users’ Personal Data, either wholly or in part, in TELKOM’s electronic and non-electronic systems. This limitation can occur upon a request to deactivate (block) and/or close Your account in accordance with the agreement between You and TELKOM.
16. “Disclosure” or “Disclose,” depending on the context and sentence structure, refers to the display, announcement, transmission, dissemination, and/or granting of access to Your Personal Data, Your End Users’ Personal Data, and/or other information.
17. “Third Parties” refer to parties such as but not limited to; TELKOM partners, contractors, vendors, agents, TELKOM affiliates.
18. “Terms and Conditions of OCA services” refers to the agreement between You and TELKOM regarding the use of OCA services.
19. OCA Page refers to the page/site used to access or visit OCA services, namely https://ocaindonesia.co.id/home or any other page for accessing OCA services for registered users.

B. ACQUISITION AND COLLECTION OF PERSONAL DATA

1. TELKOM acquires and collects Your Personal Data and/or Your End Users’ Personal Data, both General and Specific/Sensitive Personal Data, in the following ways:
   1. Direct submission by You, such as:
      1. When You create an OCA service account (sign-up/account creation) or use OCA services, including but not limited to Your name, email address, and phone number used to access OCA services after account creation/registration;
      2. When You contact TELKOM Contact; and
      3. When You update (refresh) Your Personal Data and/or Your End Users’ Personal Data previously stored by TELKOM;
   2. Automatic acquisition and collection from activities You carry out on the OCA Page or while using services or facilities provided by TELKOM, particularly OCA services, including but not limited to:
      1. If You use OCA services with a registered or verified account through a payment facility by providing Personal Data including but not limited to Your full name, Your identity card number, the type of identity card used for registration, Your place of residence and/or Your company’s address, Your company’s industry type, Your company’s country of origin, and Your company’s postal code.
      2. If You make payments or transfers using electronic money and/or an electronic wallet facility provided by TELKOM, and You are the payer, You agree to provide TELKOM with information relating to the usage, payment, or transfer, including but not limited to payment parties (online payment, e-money, or virtual bank), transfer details, and/or payment recipient, billing address (customer personal details), order summary, and the amount paid.
   3. Acquisition and collection from Third Parties who store Your Personal Data and/or Your End Users’ Personal Data; and
   4. Acquisition and collection by other means and from any available source, as long as not prohibited by applicable laws and regulations.
2. You hereby acknowledge and agree to provide and authorize TELKOM to acquire and collect Your Personal Data and/or Your End Users’ Personal Data and/or other related data or information by the means described in point 1 above for the purposes specified in this Privacy and Personal Data Protection Policy.
3. You must always ensure that Your Personal Data and/or Your End Users’ Personal Data submitted to TELKOM is correct, complete, accurate, and not misleading. You should notify TELKOM of any changes to Your Personal Data and/or Your End Users’ Personal Data before the changes take effect. Any incompleteness, invalidity, inaccuracy, and/or misleading information regarding Your Personal Data and/or Your End Users’ Personal Data submitted to TELKOM may constitute a failure on Your part to comply with legal or contractual obligations, depending on the circumstances. You hereby release TELKOM from all consequences arising from Your negligence or error in maintaining the accuracy, completeness, and correctness of Your Personal Data and/or Your End Users’ Personal Data, and Your failure to maintain the validity, completeness, and accuracy of the Personal Data submitted to TELKOM.
4. When submitting Your Personal Data and/or Your End Users’ Personal Data, You hereby represent and warrant that You are legally competent to submit Personal Data to TELKOM, and if:
   1. You are an individual under 21 (twenty-one) years old and have never been married, TELKOM assumes that the submission of Your Personal Data and/or Your End Users’ Personal Data has been approved by Your legal parents, guardians, or custodians to represent You;
   2. You are a corporate entity or an organization, TELKOM assumes that the submission of Your Personal Data and/or Your End Users’ Personal Data is made by an authorized representative to submit the Personal Data in question to TELKOM, such as but not limited to; a proxy or director; and
   3. You are a legally competent individual but Your Personal Data and/or Your End Users’ Personal Data is submitted by a proxy, TELKOM assumes that the submission of Your Personal Data and/or Your End Users’ Personal Data is made by a legally appointed proxy to represent You.

C. PURPOSE OF PERSONAL DATA PROCESSING

TELKOM processes Your Personal Data and/or Your End Users’ Personal Data, both General and Specific/Sensitive Personal Data, for the following purposes:

1. Documentation and background checks on You. TELKOM is required to conduct due diligence, background checks on You, and assess/analyze the risks to avoid legal risks, risks related to money laundering, or terrorist financing.
2. Provision and improvement of OCA services.
3. Legal actions taken by or against TELKOM and/or TELKOM Affiliates, particularly when TELKOM engages in corporate actions or is the subject of a corporate action, such as mergers, consolidations, acquisitions, asset sales, restructuring, divestitures, and/or financing.
4. Processing the use of OCA services that You undertake.
5. Sending information that TELKOM deems useful to You, including information about TELKOM services or services provided by Third Parties in collaboration with TELKOM, updates, developments, and/or enhancements of OCA services.
6. Personalizing Your account on the OCA Page for Your maximum benefit, as provided by TELKOM and/or Third Parties collaborating with TELKOM.
7. Billing, account management, and other administrative purposes. TELKOM may need to contact You for invoicing, account management, and similar reasons, and TELKOM uses Your account data to manage accounts and track billing and payments.
8. Internal administrative purposes, particularly for (i) audits, (ii) data analysis for testing, research, analysis, product development, commercial partnerships, and related collaboration purposes, and/or (iii) records in the database.
9. Ensuring the security of the OCA Page.
10. TELKOM’s compliance with obligations imposed by Authorized Authorities or applicable laws and regulations as advised, recommended, expected, or requested by TELKOM’s legal counsel and/or Authorized Authorities, including disclosures made pursuant to subpoenas, judgments, and/or court orders, orders from law enforcement authorities for investigations or other legal processes, or requirements applicable to TELKOM or TELKOM Affiliates (especially regarding suspected criminal activities like embezzlement, fraud, or data theft, anti-money laundering, and reporting requirements for counter-terrorism funding).
11. Processing Your requests regarding access, correction, updating, and/or deletion/destruction of Your Personal Data and/or Your End Users’ Personal Data in TELKOM’s systems, and contacting You regarding Your request to TELKOM.
12. Other purposes as long as they are not prohibited by applicable laws and regulations. To avoid doubt, TELKOM will notify You of other purposes when requesting Your consent unless otherwise specified by applicable laws and regulations.

D. DISCLOSURE OF PERSONAL DATA

1. In certain circumstances, TELKOM must disclose Your Personal Data and/or Your End Users’ Personal Data for the following purposes and any other purposes permitted by applicable laws and regulations:
   1. To fulfill obligations, responsibilities, or orders arising from applicable laws and regulations or from orders of Authorized Authorities, including but not limited to: investigative needs, compliance with court orders for legal processes, or to comply with archiving or reporting obligations under applicable regulations, and for other purposes as required by applicable laws and regulations (if any).
   2. To address or resolve an emergency situation concerning Your safety, Your End Users’ safety, and/or TELKOM’s interests, particularly (i) to prevent loss or financial harm, to report suspected illegal activities, or to respond to any claims or potential claims made against TELKOM and/or TELKOM affiliates; or (ii) if You Lose Your Personal Data and/or Your End Users’ Personal Data stored on Your own, and You request assistance from law enforcement or other parties to recover Your Personal Data and/or Your End Users’ Personal Data stored by TELKOM, then to assist You, TELKOM may submit Your Personal Data and/or Your End Users’ Personal Data to law enforcement or other parties for the purpose of helping You recover Your lost Personal Data and/or Your End Users’ Personal Data.
   3. To carry out public interests. TELKOM may provide Your Personal Data and/or Your End Users’ Personal Data to Authorized Authorities and/or other parties designated by Authorized Authorities, for purposes including but not limited to: contact tracing, supporting initiatives, policies, or programs of the Authorized Authorities, and for other purposes as reasonably required.
   4. For activities such as mergers, consolidations, acquisitions, asset sales, restructuring, or financing involving TELKOM as the party conducting the activity with another party or as TELKOM being merged or consolidated with another company, or acquired by another company or receiving financing from another company.
   5. The use of Personal Data by Third Parties in the context of providing, testing, researching, analyzing, selling, marketing, offering, or improving the quality of Third-Party products or services in collaboration with TELKOM, which in such collaboration, the Third Parties require the transmission and/or disclosure of Your Personal Data and/or Your End Users’ Personal Data. These products or services include but are not limited to: Know Your Customer (KYC), audit services, marketing services or marketing platforms, complaint handling services, insurance, and other financial services.
   6. To carry out collaboration with Third Parties to (i) assist TELKOM in providing TELKOM’s services; (ii) operate TELKOM’s business; (iii) for data processing purposes on behalf of TELKOM; (iv) for internal audit purposes; (v) to enable the purchase of and/or access to goods and/or services offered by Third Parties on the OCA Page; (vi) to process all forms of Your activity on the OCA Page; and/or (vii) for other purposes, as long as they are not prohibited by applicable laws and regulations. All Third Parties collaborating with TELKOM are committed to processing the Personal Data they receive from TELKOM in accordance with applicable laws and regulations.
2. Regarding Third Parties who are TELKOM affiliates, You hereby agree that TELKOM may disclose Your Personal Data and/or Your End Users’ Personal Data to those Third Parties, and these Third Parties may send, transmit, and/or provide Your Personal Data and/or Your End Users’ Personal Data to other parties with whom such Third Parties cooperate (as relevant), particularly in order to forward Your request for support services that You want from other parties, as support service providers for OCA services.
3. Concerning the disclosure of Your Personal Data to Third Parties, including from Third Parties to other parties, TELKOM will require those Third Parties and other parties to maintain the security and confidentiality of Your Personal Data and/or Your End Users’ Personal Data in accordance with the applicable laws and regulations. If the relevant Third Parties do not require certain Personal Data to be associated with You, the relevant Personal Data will be reasonably deleted so that the Personal Data can no longer be linked to You as an individual before it is disclosed or transferred to such Third Parties.
4. In the utilization of the OCA Interaction service, the management of and access to End Users’ Personal Data are governed by a role-based access control system. By default, all accounts, regardless of their assigned role, possess full access to End Users’ Personal Data, including names and other basic identifiers. However, such access may be restricted and/or customized for accounts designated as Agent and/or Non-Agent roles through access control configurations managed by Administrator or Supervisors (SPV) accounts. These configurations are determined based on operational necessity, service utilization, and established data protection standards. This Policy is implemented as part of TELKOM commitment to safeguarding End Users’ Personal Data and ensuring strict compliance with all applicable laws and regulations.

E. COLLECTION OF PERSONAL DATA FROM THIRD PARTIES

1. TELKOM may also collect Your Personal Data and/or Your End Users’ Personal Data from Third Parties who collaborate with TELKOM to assist, facilitate, operate, provide, enhance, understand, customize, support, and market OCA services. In such cases, TELKOM will only collect Your Personal Data and/or Your End Users’ Personal Data for purposes involving such Third Parties or for the implementation of TELKOM’s collaboration with those Third Parties.
2. In the event that TELKOM receives Your Personal Data and/or Your End Users’ Personal Data from Third Parties, TELKOM assumes that the submission of Your Personal Data to TELKOM by such Third Parties has been previously approved by You, and TELKOM cannot be held accountable in any form if such Third Parties submit Your Personal Data and/or Your End Users’ Personal Data without Your prior consent.

F. COLLECTION OF INFORMATION FROM OTHER PARTIES

1. In certain circumstances, TELKOM may request that You provide or submit information about other parties to fulfill purposes not prohibited by applicable laws and regulations. The other parties’ information as referred to may include the Personal Data of representatives (if You are a legal entity or civil partnership), such as but not limited to; directors, commissioners, employees, or the Personal Data of spouses, family members, and/or colleagues (if You are an individual).
2. TELKOM may process such other parties’ information once TELKOM receives it from You, for purposes that are not prohibited by applicable laws and regulations.
3. The processing of such other parties’ information, as long as it can be categorized as Personal Data, will be carried out by TELKOM in accordance with this Privacy and Personal Data Protection Policy.

G. SECURITY OF PERSONAL DATA

1. TELKOM will protect and secure Your Personal Data and/or Your End Users’ Personal Data, both General and Specific/Sensitive Personal Data, stored in TELKOM’s storage systems (including restricting access to Your Personal Data and/or Your End Users’ Personal Data to TELKOM employees based on the need to know. The processing of Your Personal Data and/or Your End Users’ Personal Data will only be carried out in a manner permitted and required to protect Your Personal Data and/or Your End Users’ Personal Data) from unauthorized processing and from processing that is in violation of applicable laws and regulations, accidental loss, destruction, or similar accidental risks by taking and applying reasonable legal, organizational, and technical measures.
2. TELKOM’s storage of Your Personal Data: TELKOM will store Your Personal Data and/or Your End Users’ Personal Data in TELKOM’s storage systems for as long as:
   1. The storage of Your Personal Data and/or Your End Users’ Personal Data is necessary to fulfill the purposes set forth in this Privacy and Personal Data Protection Policy;
   2. The storage of Your Personal Data and/or Your End Users’ Personal Data is permitted or required by applicable laws and regulations;
   3. You do not request the deletion/destruction of Your Personal Data stored by TELKOM, or You do not withdraw Your consent for TELKOM to store Your Personal Data and/or Your End Users’ Personal Data;
   4. Your request for the deletion/destruction of Your Personal Data stored by TELKOM has been denied by TELKOM based on considerations stipulated in this Privacy and Personal Data Protection Policy; and/or
   5. TELKOM has the right to retain and use Your Personal Data and Your End Users’ Personal Data for up to a maximum of 5 (five) years if there is no request for the deletion/destruction of the Personal Data from You. TELKOM also uses a database with third-party infrastructure and servers and uses licensed software.
   6. For those of you with a free trial account, TELKOM will automatically delete your account 30 (thirty) days after your free trial period has ended.
3. Personal Data stored by Authorized Authorities:
   1. TELKOM may be required by applicable laws and/or Authorized Authorities to submit or share Your Personal Data and/or Your End Users’ Personal Data with Authorized Authorities and/or other parties designated by Authorized Authorities.
   2. Regarding point (a) above, You hereby agree and acknowledge that the storage of Your Personal Data and/or Your End Users’ Personal Data by Authorized Authorities and/or other parties designated by Authorized Authorities will follow the data storage policies and standards applied by Authorized Authorities and/or other parties designated by Authorized Authorities.
   3. You hereby acknowledge and agree that TELKOM is not responsible for the security and confidentiality of Your Personal Data and/or Your End Users’ Personal Data stored by Authorized Authorities and/or other parties designated by them and releases TELKOM from any claims regarding security and confidentiality violations related to Your Personal Data and/or Your End Users’ Personal Data stored by Authorized Authorities and/or other designated parties.
4. Prudence Principle:
   1. TELKOM strongly encourages You to be very cautious in safeguarding the security and confidentiality of Your Personal Data and/or Your End Users’ Personal Data, including by:
   2. Internet Usage: You should be aware that using the internet to transmit, share, upload, or send Your Personal Data and/or Your End Users’ Personal Data is not entirely secure, as the internet can be accessed by anyone and there are risks associated with the provision and use of the internet that are beyond TELKOM’s control. Providing Your Personal Data and/or Your End Users’ Personal Data through the internet is at Your own risk. Please always be cautious when using the internet for Your Personal Data and/or Your End Users’ Personal Data.
5. Disclaimer of Responsibility: TELKOM is not liable in any form for:
   1. The validity of Your End Users’ Personal Data, so any legal issues arising from the invalidity of Your End Users’ Personal Data are Your responsibility.
   2. The security and confidentiality of Your Personal Data and/or Your End Users’ Personal Data that You store Yourself or provide to Third Parties or other parties;
   3. The security and confidentiality of Personal Data that has been publicly disclosed or disclosed to Third Parties, whether the disclosure was made by You or any other party besides TELKOM, and such disclosure occurred not due to TELKOM’s negligence or error in protecting Your Personal Data and/or Your End Users’ Personal Data;
   4. All consequences arising from Your negligence in maintaining the security and confidentiality of Your Personal Data and/or Your End Users’ Personal Data; and
   5. All consequences arising from the use of any media You use to store, upload, send, transmit, and/or share Your Personal Data and/or Your End Users’ Personal Data, such as the internet or cloud storage services.

H. ACCESS, CORRECTION, AND UPDATING OF PERSONAL DATA

1. You may request TELKOM to:
   1. Provide Your Personal Data and/or Your End Users’ Personal Data and/or give You access to Your Personal Data and/or Your End Users’ Personal Data stored in TELKOM’s storage system;
   2. Correct Your Personal Data and/or Your End Users’ Personal Data stored in TELKOM’s storage system; and/or
   3. Update Your Personal Data and/or Your End Users’ Personal Data stored in TELKOM’s storage system.
2. If TELKOM provides Your Personal Data and/or Your End Users’ Personal Data to You, TELKOM will do so electronically, and Your Personal Data and/or Your End Users’ Personal Data will be provided in an electronic format or another form and method as determined by TELKOM from time to time.
3. TELKOM reserves the right to reject Your request as outlined in point 1 of this section, either partially or in full, if:
   1. Your request is irrelevant to the Personal Data stored by TELKOM, such as if You request Personal Data regarding another party over whom You do not have authority; and/or
   2. TELKOM is not permitted by Authorized Authorities and/or applicable laws and regulations to fulfill Your request.
4. Updating Your Personal Data and/or Your End Users’ Personal Data:
   1. You are required to update Your Personal Data when there is a change to Your Personal Data that You have submitted to TELKOM. TELKOM needs You to update Your Personal Data for security, Personal Data relevance, and anti-money laundering and counter-terrorism purposes.
   2. AYou are required and responsible for updating Your End Users’ Personal Data when there is a change to Your End Users’ Personal Data that You have submitted to TELKOM. Updating Your End Users’ Personal Data is also done for security, Personal Data relevance, and anti-money laundering and counter-terrorism purposes.
   3. You are also required to promptly update Your Personal Data and Your End User’s Personal Data if TELKOM requests You to update such Personal Data for one or more of the following reasons:
      1. TELKOM identifies changes to Your Personal Data and/or Your End Users’ Personal Data that You have previously submitted to TELKOM;
      2. TELKOM identifies indications of changes in Your usage patterns of OCA services or significant risk increases based on TELKOM’s customer due diligence (‘CDD’) performed on You as a user of OCA services; and/or
      3. TELKOM identifies indications of money laundering, terrorist financing, and/or other legal violations.
   4. If TELKOM requests You to update Your Personal Data and/or Your End Users’ Personal Data for the reasons mentioned in point (c) above, TELKOM will inform You and provide a deadline for You to update such Personal Data.
   5. If You fail to update Your Personal Data and/or Your End Users’ Personal Data in a valid, accurate, complete, and clear manner after the deadline provided in point (d) above, TELKOM reserves the right to temporarily suspend Your OCA services.
   6. Referred to point 1 letter (c) of these Terms, specifically regarding the update of Your Personal Data which cannot be conducted independently by You through the OCA Page, You are required to submit a request for the update of Your Personal Data to OCA via Contact Support.
   7. In the event You utilize OCA AI and OCA Interaction services concurrently, You acknowledge and agree that two services are mutually integrated. Any updates made to Your Personal Data on one service’s dashboard by an account by Administrator role will automatically result in a corresponding update on the dashboard of the other service.

I. CONSENT

1. By agreeing to this Privacy and Personal Data Protection Policy, You acknowledge and declare that You have read and understood the terms and conditions of this Privacy and Personal Data Protection Policy. Specifically, You grant TELKOM consent to process Your Personal Data and/or Your End Users’ Personal Data in accordance with the provisions of this Privacy and Personal Data Protection Policy.
2. You are deemed to have given Your consent to the applicability of this Privacy and Personal Data Protection Policy to You if one or more of the following conditions occur:
   1. You are registered as a user of OCA services;
   2. You submit Your Personal Data and/or Your End Users’ Personal Data to TELKOM for the purpose of processing Your Personal Data and/or Your End Users’ Personal Data as stipulated in this Privacy and Personal Data Protection Policy;
   3. Your Personal Data and/or Your End Users’ Personal Data is stored in TELKOM’s storage system;
   4. You provide consent to an agreement or contract between You and TELKOM concerning the use of OCA services;
   5. You use the OCA Page; and/or
   6. You communicate with TELKOM.
3. This Privacy and Personal Data Protection Policy becomes effective once You provide Your consent to this Privacy and Personal Data Protection Policy, either explicitly or through the methods described in point 2 above, and will remain in effect as long as one of the conditions mentioned in point 2 above continues, or until You withdraw Your consent.
4. If You are given the option to share Your Personal Data and/or Your End Users’ Personal Data with TELKOM, You can always choose not to do so. If TELKOM has requested Your consent to process Your Personal Data and/or Your End Users’ Personal Data and You subsequently choose to withdraw Your consent, TELKOM will respect that choice in accordance with TELKOM’s legal obligations. However, choosing not to share Your Personal Data and/or Your End Users’ Personal Data with TELKOM may mean that TELKOM is unable to take the necessary actions to achieve the purpose of processing Personal Data as set forth in this Privacy and Personal Data Protection Policy, or that You will be unable to use OCA services.

J. DELETION/DESTRUCTION OF PERSONAL DATA AND WITHDRAWAL OF CONSENT

1. You have the right to withdraw Your consent for TELKOM to store Your Personal Data and/or Your End Users’ Personal Data, whether General or Specific/Sensitive Personal Data. With such withdrawal of consent, TELKOM will delete/destroy Your Personal Data and/or Your End Users’ Personal Data from TELKOM’s storage systems and cease processing Your Personal Data and/or Your End Users’ Personal Data.
2. In addition to the provisions in point 1 of this paragraph, your Personal Data may also be deleted/destroyed from TELKOM’s storage system if:
   1. The retention period for your Personal Data and/or the Personal Data of End Users has expired, which is after 5 (five) years following the contract;
   2. The subscription and/or cooperation contract has expired if there has been no request for deletion/destruction of Personal Data from you;
   3. Your Personal Data and/or the Personal Data of End Users is no longer needed, and the deletion/destruction of such Personal Data is permitted by applicable laws and regulations;
   4. You request TELKOM to delete/destroy your Personal Data and/or the Personal Data of End Users stored in TELKOM’s storage system, either partially or entirely, by sending a written request to TELKOM Contact;
   5. TELKOM is prohibited from retaining your Personal Data and/or the Personal Data of End Users based on applicable laws and/or orders from the Competent Authority; and/or
   6. Your free trial account usage has concluded, which is 30 (thirty) days after the free trial period ends.
3. The deletion/destruction of Your Personal Data and/or Your End Users’ Personal Data from TELKOM’s storage systems or the withdrawal of Your consent for TELKOM to store Your Personal Data and/or Your End Users’ Personal Data will prevent TELKOM from:
   1. Further processing your registration, if You are a prospective user in the process of registering an account; and/or
   2. Processing Your use of OCA services if You are a user. If TELKOM does not store Your Personal Data and/or Your End Users’ Personal Data, TELKOM will be unable to perform activities related to the processing of OCA services, such as sending SMS blasts and others.
4. Specifically for requests for Deletion/Destruction and/or withdrawal of consent related to Personal Data required for the use of the OCA Service, such deletion/destruction and/or withdrawal of consent must be mutually agreed upon by you and TELKOM. This provision is exempted if the deletion/destruction is ordered by applicable laws and/or the Competent Authority.
5. TELKOM reserves the right to refuse your request for the Deletion/Destruction of your Personal Data, as referred to in point 1 above, either partially or entirely, if:
   1. Your Personal Data and/or the Personal Data of End Users has already been deleted/destroyed from TELKOM’s storage system based on a similar request you made previously, and/or at the request of the Competent Authority to TELKOM;
   2. Your request is not relevant to the Personal Data of yours and/or the Personal Data of End Users stored by TELKOM, such as if you request Personal Data regarding another party for which you do not have authority over that Personal Data; and/or
   3. TELKOM is not permitted by the Competent Authority and/or applicable laws to fulfill your request.
6. In connection with the Deletion/Destruction and withdrawal of consent as referred to in this section, you hereby agree to release TELKOM from any liability in any form for all consequences arising from such Deletion/Destruction and withdrawal of consent.

K. ANONYMOUS DATA

1. You hereby agree that TELKOM has the right to remove data that identifies You and/or Your End Users from Your Personal Data and/or Your End Users’ Personal Data or to combine Your Personal Data and/or Your End Users’ Personal Data with other data, so that the data containing identification of You and/or Your End Users or that can be linked to You and/or Your End Users in Your Personal Data and/or Your End Users’ Personal Data is removed or merged with other data, causing such data to no longer be identifiable to You and/or Your End Users either as individuals or as entities and become Anonymous Data.
2. You hereby agree that TELKOM has the right to continuously store, send, disclose, process, utilize, and delete/destroy Anonymous Data, given that Anonymous Data is no longer Your Personal Data and/or Your End Users’ Personal Data and can no longer be identified as pertaining to You.

L. SPECIFIC/SENSITIVE PERSONAL DATA

You hereby agree that TELKOM has the right to continuously obtain, collect, store, process, disclose, utilize, use, manage, transfer, protect, and delete/destroy Your Specific/Sensitive Personal Data and/or Your End Users’ Specific/Sensitive Personal Data for the purposes set forth in this Privacy and Personal Data Protection Policy. This Specific/Sensitive Personal Data includes details such as bank account information, credit/debit card numbers, personal financial information, children’s Personal Data, biometric data, criminal records, and transaction data that is combined with or contains Personal Data.

M. THIRD-PARTY PLATFORMS

1. You should be aware that OCA services may be available on Third-Party platforms (websites) that collaborate with TELKOM.
2. You acknowledge and agree that (i) Third-Party platforms are managed and operated independently by those Third Parties, and (ii) TELKOM will be released from any liability for the Processing of Your Personal Data and/or Your End Users’ Personal Data by Third Parties, as described in point 1 of this section.
3. If You provide Your Personal Data and/or Your End Users’ Personal Data to TELKOM through these Third-Party platforms, You agree that the privacy policies and service terms on those platforms will apply, and TELKOM will be released from any liability for the Processing of Personal Data conducted by those Third Parties or as regulated by the privacy policies and service terms on those platforms.

N. COOKIES, MARKETING MATERIALS, AND PROMOTIONS

1. In connection with Your use of the OCA Page, You agree that TELKOM and/or Third Parties collaborating with TELKOM may use cookies and other similar identifying technologies to collect Your Personal Data and/or Your End Users’ Personal Data for purposes not prohibited by applicable laws.
2. You agree that TELKOM and/or Third Parties collaborating with TELKOM may send You direct marketing and promotional materials such as advertisements and/or promotional communications via email or other available communication channels.
3. You have the right to limit the collection of cookies on the OCA Page, as described in point 1 above, by:
   1. Adjusting Your browser’s cookie settings;
   2. Deleting Your browsing history; and/or
   3. Clearing the cache from Your web browser.
4. You have the right to opt out of receiving such marketing and promotional materials to Your email or contact, as described in point 2 above, by:
   1. Clicking the unsubscribe button on the marketing and promotional materials You receive;
   2. Contacting TELKOM Contact and expressing Your objection regarding the sending of marketing and promotional materials to Your email or contact.

O. YOUR RIGHTS

1. You have the right to access and obtain copies of Your Personal Data in accordance with applicable laws..
2. In the event of negligence caused by TELKOM, You have the right to sue and receive compensation for violations in the processing of Your Personal Data in accordance with applicable laws.
3. You have the right to obtain and/or use Your Personal Data from TELKOM in a format that complies with commonly used structures and/or formats readable by electronic systems.
4. You have the right to use and send Your Personal Data to other third parties, as long as the systems used can securely communicate in accordance with the principles of Personal Data Protection based on applicable laws, and TELKOM is not responsible for actions You have taken.
5. TELKOM processes Your Personal Data and/or Your End Users’ Personal Data in accordance with applicable laws. Therefore, without prejudice to other provisions in this Privacy and Personal Data Protection Policy, TELKOM respects Your rights as guaranteed by applicable laws. To the extent possible under applicable laws, You can exercise Your rights by contacting TELKOM and providing details of the type and identity of Your rights.
6. TELKOM reserves the right to refuse the exercise of the rights You request based on factual verification results that we conduct and/or for other reasons permitted by applicable laws in the field of Personal Data Protection.

P. OTHER PROVISIONS

1. Changes:
   1. TELKOM may review and amend this Privacy and Personal Data Protection Policy at its discretion to ensure that the provisions of this Privacy and Personal Data Protection Policy are consistent with TELKOM’s future developments, and/or if there are changes in laws and/or orders from Authorized Authorities for TELKOM to immediately amend the provisions in this Privacy and Personal Data Protection Policy.
   2. TELKOM will notify You of any changes as referred to in point (a) above through a public notice on the OCA Page, or via specific notifications to Your registered email or contact number in TELKOM’s system.
   3. You agree that You are solely responsible for reviewing this Privacy and Personal Data Protection Policy periodically to learn about the latest information regarding this Privacy and Personal Data Protection Policy via the OCA Page and/or Your registered email and/or contact number in TELKOM’s system. Please periodically and regularly visit the OCA Page, and keep Your email and/or contact number active and accurate, and check Your email and/or contact number regularly to ensure You are informed about TELKOM’s Privacy Policy from time to time.
   4. By remaining:
      1. Registered as either a paid or unpaid user;
      2. Submitting Your Personal Data and/or Your End Users’ Personal Data to TELKOM or allowing TELKOM to store and process Your Personal Data and/or Your End Users’ Personal Data;
      3. Using OCA services;
      4. Having and/or entering into agreements or contracts with TELKOM, such as the Terms of Use for OCA services;
      5. Visiting and/or using the OCA Page; and/or
      6. Communicating with TELKOM.

      You agree to the changes that TELKOM has enacted.

   5. You must ensure that Your registered contact information with TELKOM is accurate and always active to avoid failure in receiving notifications.
2. Invalidity: The cancellation of any provision in this Privacy and Personal Data Protection Policy due to the enactment of a law or other reasons shall not automatically invalidate the provisions of this Privacy and Personal Data Protection Policy.
3. TELKOM Contact: If You have any questions or complaints regarding the implementation of this Privacy and Personal Data Protection Policy, You can contact TELKOM through the TELKOM Contact listed below:Phone number: +62 8111 0691 011
4. Language: This Privacy Policy may be issued in both Indonesian and English. In the event of any discrepancies between the Indonesian and English versions, the Indonesian version shall prevail.
5. Governing Law: All provisions in this Privacy and Personal Data Protection Policy are subject to and interpreted in accordance with the laws applicable in the Republic of Indonesia.