Privacy Policy

PT Manulife Aset Manajemen Indonesia (“MAMI”) collects personal data from clients and prospective clients (“You”) to fulfill our responsibilities as a financial services provider. This enables us to deliver customer services and manage your investments through the various products we offer.

We understand that your privacy and the use of your personal information are important. Therefore, we have established provisions regarding how your personal data is processed, what rights you have, and how you can access further information about our Privacy Policy.

Personal data refers to information about you, such as your name, date of birth, contact details, and bank account information. We collect your personal data to provide customer services and deliver the products you require, as well as to comply with applicable regulations. If you choose not to provide certain personal data necessary for us to deliver a service or product, we may be unable to proceed with that service or product.

We may update this Privacy Policy from time to time by revising the Privacy Policy page on our website. If there are changes to the Privacy Policy, we will notify you and, where required, obtain your prior consent. Therefore, we encourage you to review our Privacy Policy on our website periodically.

This Privacy Policy does not override the provisions stated in the Manulife Mutual Fund prospectus, which governs mutual funds issued and managed by MAMI, nor does it affect any rights you have under applicable personal data protection laws.

Details of Personal Data We Process

The personal data we process includes, but is not limited to:

• Personal and contact information such as full name, phone number, address, email, date and place of birth, gender, employment details, and/or financial information;
• Copies of your identification documents and the information contained therein;
• Information regarding your employment status, position, and the institution where you work;
• Information about your financial details, such as salary and other sources of income;
• Information obtained from financial analysis or customer risk profiling;
• Information regarding the beneficial owner, if any, for the purpose of complying with Know Your Customer (KYC) requirements;
• Your tax status information required for tax reporting purposes in accordance with applicable regulations;
• Products and services you use, and payment methods, including transaction history related to the purchase, redemption, and transfer of Reksa Dana Manulife investment units you own;
• Information about MAMI products or services you may access through our marketing partners;
• Information related to fraud, debt, and money theft that may be associated with you, as well as the devices used for such activities;
• Other personal information collected for the purpose of providing services related to the Reksa Dana Manulife you own or as required to comply with applicable laws and regulations governing MAMI; 
• If you use online/digital services operated or provided by MAMI (such as our website), the personal data we collect may include browser type, device type, operating system, and date and time of access;
• Records of your communications with us, including those captured through our customer service phone number and, if you contact us online using our digital services (e.g., online chat), the IP address you use;
• Any other personal information you provide to us.

How We Collect Your Personal Data

We collect personal data from the following sources:

• Directly from you, when you open an account and conduct transactions related to Manulife Mutual Funds;
• From third parties, such as marketing agents, distributors, and business partners who collaborate with us to provide products, services, or offers to you, or from other parties after obtaining your consent;
• Cookies and IP addresses, when you visit our website or complete a contact form on our website.

How We Use Your Personal Data and the Legality of Processing Your Personal Data

We only use and store your personal data for its intended purposes, for any other purposes you have consented to, and to fulfill legal obligations as stipulated under Law No. 27 of 2022 on Personal Data Protection and relevant regulations issued by the Otoritas Jasa Keuangan (OJK).

We will use the personal data we collect for the following purposes:

• Administrative processes and services related to your Manulife Mutual Fund products, enabling us to fulfill our obligations as your investment manager, including but not limited to:

a.        Opening your investment account with MAMI;

b.        Creating a Single Investor Identification (SID) with the Kustodian Sentral Efek Indonesia (KSEI);

c.        Processing transactions for purchase, redemption, and transfer of investment units;

d.        Updating customer data;

e.        MAMI operational activities;

f.         Customer service, including handling inquiries and complaints.

• Providing customer services, including but not limited to responding to information requests and notifying you of any changes related to the products and services you own.
• Storing your information for administrative purposes and other internal business processes.
• Compliance with applicable regulations governing MAMI or the Manulife Group, including but not limited to anti-money laundering and counter-terrorism financing regulations, fraud prevention, and other financial crime requirements, as well as reporting to relevant authorities.
• Designing and offering other products and services that may align with market conditions and customer needs.
• Automated decision-making or profiling, which does not result in legal consequences or have a significant impact on you.

Statistical or trend analysis using advanced technologies, where we may process personal data in an anonymized form by combining or aggregating existing data with other information collected for the purposes above. We will continue to protect the confidentiality and security of personal data we hold, store, or control by: (i) Limiting access to such personal data; and (ii) Implementing reasonable administrative, technical, and physical safeguards to prevent loss, misuse, or unauthorized and unlawful disclosure.

Additionally, we may use and disclose your personal data, together with other information, to third parties (such as our affiliated companies) to send you direct marketing offers for our products and services via telephone, email, social media, or other electronic channels, or to introduce products and services from carefully selected affiliates. To carry out these activities, we will obtain your consent. If you wish to withdraw your consent, you may contact MAMI Customer Service by phone at 021 2555 2255 or by email at hai@manulifeam.com.

Retention and Processing of Your Personal Data

Your personal data will be processed for as long as you remain a customer of MAMI. We will cease processing your personal data once you are no longer a MAMI customer.

MAMI’s policy requires us to retain your personal data for the duration of your relationship with us and for up to seven (7) years after the purpose for which the data was collected has been fulfilled, including after the relationship ends due to the closure of your investment account with MAMI.

However, we may retain your personal data for a longer period under certain circumstances, such as: (i) when we are required or permitted to do so under applicable laws, tax, accounting regulations, and/or by competent authorities; (ii) in the event of complaints or disputes, where we need to maintain accurate records of your relationship with us; or (iii) when we anticipate potential legal claims that relate to or require the processing of your personal data.

When your personal data is no longer needed, we will ensure that it is either securely destroyed or stored in a manner that renders it no longer identifiable or usable for business purposes.

Your Rights as a Personal Data Subject

In relation to how we use and process your personal data, you have the right to:

• Request access to and obtain a copy of your personal data;
• Request that we complete, update, and/or correct any errors or inaccuracies in your personal data in accordance with the purpose of processing;
• Request that we terminate processing, delete, or destroy your personal data, withdraw your consent for processing, and/or delay or restrict the processing of your personal data.

MAMI reserves the right to refuse such requests if they do not comply with applicable regulations. Please note that certain personal data is necessary for us to provide our services. Therefore, if you request termination of processing, deletion, destruction, withdrawal of consent, or restriction of processing that prevents us from processing your personal data, this may affect our ability to deliver services to you.

We encourage you to contact MAMI Customer Service to discuss the implications of such requests before submitting them.

Your rights as a data subject, as described above, are subject to the laws and regulations of the Republic of Indonesia.

To provide consent, verify, or request corrections to your personal data, please contact MAMI Customer Service. You may also do so independently by logging into your account on our website. MAMI Customer Service can also assist you if you wish to submit a request to withdraw consent, obtain access and/or copies, or raise objections regarding the processing of your personal data.

Last Updated: September 2024