PT Synnex Metrodata Indonesia

PRIVACY STATEMENT

1. Your rights in relation to privacy

   PT Synnex Metrodata Indonesia (Synnex) understands the importance of protecting the privacy of an individual’s personal information and is committed to protecting your privacy.

   This statement sets out how Synnex aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Synnex and the way Synnex collects, holds, uses and discloses your personal information. This policy statement may be updated from time to time.

   In handling your personal information, Synnex will comply with PERATURAN PEMERINTAH REPUBLIK INDONESIA NOMOR 82 TAHUN 2012 TENTANG PENYELENGGARAAN SISTEM DAN TRANSAKSI ELEKTRONIK.

2. What kinds of personal information does Synnex collect?

   Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its services, Synnex may collect your personal information.

   Generally, the kinds of personal information Synnex collects are:

   • contact and identification information such as your name and previous names, address and previous addresses, telephone number, email address, facsimile number, date of birth, gender
   • employment information such as your current and previous places of employment;
   • banking details and/or credit card details where necessary to facilitate direct debit payments;
   • information about your computer hardware and software, including IP addresses, domain names, access times and accessed website addresses to the extent this information constitutes personal information;
   • credit information, where relevant to Synnex’s assessment of an application to become a Synnex authorised reseller, including where you have applied to guarantee any payments under such a dealer account, being credit-related personal information lawfully created and accessible within the Indonesia credit reporting system including:
     • identification information;
     • consumer credit liability information which includes information about credit providers and credit accounts, including the dates on which the accounts are opened and closed, their terms and conditions (or changes to the terms and conditions) and the maximum limit of credit available under an account;
     • information about your repayment history, including whether you have made payments when due, and if not, when overdue payments have been made;
     • whether you have defaulted on a payment (ie. a payment that is at least 60 days overdue);
     • whether you have paid any amount previously reported as being in default;
     • information about any debt collection activities which is carried on by any mercantile agents.
     • information about other credit providers having sought credit-related information about you from a credit reporting body;
     • information about the types of consumer or commercial credit, and the amounts of credit, you have sought in an application;
     • information about court proceedings that relate to credit provided to you or for which you have applied;
     • information regarding your land title holdings and valuations of such land;
     • personal insolvency information about you;
     • publicly available information relating to your credit worthiness;
     • information about a credit provider’s opinion that you have committed a serious credit infringement in relation to consumer credit provided by that credit provider to you;
     • any other information lawfully obtainable within the Indonesia credit reporting system;
   • any additional information Synnex derives from credit eligibility information based on its own analysis including through an internal scoring process to assess credit worthiness.
   • sensitive information including criminal record information where you are applying for a position with Synnex and where relevant to Synnex’s assessment of whether you are able to perform the inherent requirements of the particular role. In some circumstances Synnex may also hold other personal information provided by you.

3. How does Synnex collect personal information?

   Generally, Synnex collects your personal information directly from you, through the completion of a manual or online form, including a dealer application form, other interaction or exchange in person or by way of telephone, facsimile, email, post or through the use of the Synnex website. There are also occasions when Synnex collects your personal information, including credit related personal information, from other sources such as from:

   • your employer, where necessary for Synnex to provide its products and/or services to your employer through you;
   • the completion of an application form by another person or entity that lists you as a director, guarantor or trade reference, or an accountant or banker of that person or entity;
   • another credit provider or banker;
   • an information services provider;
   • a publicly maintained record or other publicly available sources of information including social media and similar websites;
   • Synnex’s own records about you, from which Synnex may internally generate its own scores, assessments or deductions, particularly in relation to your credit worthiness; and
   • if for recruitment purposes, an external recruitment or background screening services provider.
   • Synnex vendor partners reports or events

   Generally, Synnex will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.

4. Why does Synnex need your personal information?

   Synnex collects, holds, uses and discloses your personal information, including credit related personal information, where it is reasonably necessary for the purposes of:

   • identification;
   • distributing computer and telecom products throughout Indonesia, including to you or your employer and operating the Synnex website;
   • providing general statistics regarding use of the Synnex website in order to deliver customised content and advertising to customers whose behaviour indicates an interest in a particular subject area, where they have consented to receive such advertising;
   • processing an application made by you or your employer, for example, for credit, including a reseller account and if successful, administering that account;
   • to notify credit providers of your credit history, including relating to defaults;
   • to access information related to your credit worthiness and to evaluate and monitor your credit worthiness, including through internal credit scoring;
   • servicing your customer account, responding to queries by you or your employer and maintaining a relationship with you;
   • conducting market research and/or customer satisfaction research;
   • facilitating and processing payments relating to you;
   • facilitating appropriate insurance cover and assessing, processing and investigating insurance risks and/or claims relating to you;
   • accounting, billing, record keeping, systems development testing, staff training and/or other internal administrative purposes;
   • identification, prevention and investigation of, and/or co-operation with relevant law enforcement bodies in relation to, any criminal or fraudulent activity relating to you;
   • developing, establishing and administering business partnerships and other arrangements with other entities in relation to the promotion, administration and use of Synnex’s products and services;
   • identifying and informing you of products and services that may be of interest to you from Synnex or selected third parties;
   • identifying and informing you of events and training that may be of interest to you from Synnex or selected third parties;
   • assessing your application for employment with Synnex or otherwise for the purposes of engaging you as a contractor or consultant;
   • debt collection; and
   • any other legal or regulatory requirements.

   Synnex may also use your personal information for purposes related to the above and for which you would reasonably expect Synnex to do so in the circumstances, or where you have consented or the use is otherwise in accordance with law. Where personal information is used or disclosed, Synnex takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Synnex. However, without certain information from you, Synnex may not be able to provide its products and/or services to you or your employer.

   Synnex encourages you to review the privacy statements of web sites you choose to link to from the Synnex web site so that you can understand how those web sites collect, use, disclose and otherwise handle your information. Synnex is not responsible for the privacy statements or other content on web sites outside of the Synnex web site.

5. To whom does Synnex disclose your personal information?

   Synnex discloses your personal information for the purposes for which Synnex collects it. That is, generally, Synnex will only disclose your personal information for a purpose, or purposes, set out at paragraph 4. This may include disclosing your personal information to:

   • third parties engaged to perform administrative or other services, including delivery companies and mailing houses;
   • entities who perform statistical analysis on behalf of Synnex;
   • vendors or entities who perform sales out report and sales analysis;
   • people or entities considering acquiring an interest in Synnex’s enterprise or assets;
   • Synnex’s professional advisors, contractors, consultants and related bodies corporate;
   • insurance providers, insurance brokers and insurance underwriters;
   • mercantile agents;
   • debt collection providers;
   • guarantors or prospective guarantors;
   • credit providers;
   • regulatory bodies.

   In particular, Synnex may also disclose your personal information with your consent or if disclosure is required or authorised by law.

6. Overseas disclosure

   Synnex discloses your personal information for the purposes for which Synnex collects it. That is, generally, Synnex will only disclose your personal information for a purpose, or purposes, set out at paragraph 4. This may include disclosing your personal information to:

   Overseas recipients may have different privacy and data protection standards. However, before disclosing any personal information to an overseas recipient, Synnex takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Indonesia Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law. If you have any queries or objections to such disclosures, please contact Synnex’s Privacy Compliance Officer on the details set out in paragraph 11.

7. Direct marketing

   Synnex may use and disclose your personal information in order to inform you of products, services, promotions and events that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting Synnex via the contact details set out in paragraph 11 or through any opt-out mechanism contained in a marketing communication to you.

   Synnex will not use or disclose credit-related personal information for direct marketing purposes except to the extent permitted under the Privacy Act.

8. Security of your personal information

   Synnex takes steps reasonable in the circumstances to ensure that the personal information, including credit related personal information, it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. Synnex holds personal information in both hard copy and electronic forms in secure databases on secure premises (including through locks, firewalls, encryptions, such as the Secure Socket Layer protocol, log-ins and passwords, and other physical and network security measures as appropriate), accessible only by authorised staff. Credit eligibility information is stored through equally secure methods. Staff are bound by security policies and confidentiality agreements, which are regularly revised and re-issued.

   Synnex will destroy or de-identify personal information (whether through shredding hardcopy documents or permanently deleting from its systems or de-identifying electronically-held information) in circumstances where it is no longer required, unless Synnex is otherwise required or authorised by law to retain the information.

9. Use of cookies

   The Synnex website uses session ‘cookies’ which are text files placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

   Cookies used by Synnex do not contain any of your personal information but enable us to recognise the number of times you access the Synnex website through your computer so that Synnex can tailor the information made available to you with the view to making your visit to the website easier, faster and more productive.

   You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Synnex services or web sites you visit.

10. Can you access and correct the personal information that Synnex holds about you?

    Synnex takes steps reasonable in the circumstances to ensure personal information, including your credit related personal information, it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by Synnex. If at any time you would like to access or correct the personal information that Synnex holds about you, or you would like more information on Synnex’s approach to privacy, please contact Synnex via the contact details set out in paragraph 11 below. Synnex will grant access to your personal information to the extent required or authorised by the Privacy Act or other laws and take steps reasonable in the circumstances to correct your personal information where necessary and appropriate. Where necessary to resolve a request for correction of your credit related personal information, Synnex may also consult with other relevant entities. Synnex’s use or disclosure of your credit related personal information to other entities for correction purposes is permitted by the Privacy Act.

    To obtain access to your personal information:

    • you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
    • Synnex requests that you be reasonably specific about the information you require; and
    • Synnex may charge you a reasonable administration fee, which reflects the cost to Synnex, for providing access in accordance with your request.

    Synnex will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If Synnex refuses your request to access or correct your personal information, Synnex will provide you with written reasons for the refusal and details of complaint mechanisms. Synnex will nevertheless take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of Synnex.

11. How to contact us

    For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional communications, please contact Synnex’s Privacy Compliance Officer at:

    PT Synnex Metrodata Indonesia

    contact@metrodata.co.id

    Tel: 62 21 29345 800 Fax: 62 21 29345 801

12. Privacy complaints

    Please direct all privacy complaints to Synnex’s Privacy Compliance Officer. At all times, privacy complaints:

    • will be treated seriously;
    • will be dealt with promptly;
    • will be dealt with in a confidential manner; and
    • will not affect your existing obligations or affect the commercial arrangements between you and Synnex.

    Specifically, if your complaint relates to credit related personal information and/or Synnex’s failure to comply with its obligations regarding credit related personal information under the Privacy Act and/or the Credit Reporting Code:

    • Synnex will acknowledge your complaint within 7 days of receipt and endeavour to resolve it within 30 days, unless Synnex informs you otherwise and seeks your agreement in writing;
    • Synnex may consult with relevant third parties, such as credit providers, in order to sufficiently and expeditiously resolve the complaint; and

    Synnex’s Privacy Compliance Officer will commence an investigation into any complaint made by you to Synnex. You will be informed of the outcome of your complaint following completion of the investigation.