Privacy Notice

PT BNI Modal Ventura (hereinafter referred to as “BNI Ventures”), located in Jakarta Pusat at Menara BNI Lantai 2 Jalan Pejompongan Raya No. 7, is committed to protecting all Personal Data processed by BNI Ventures to ensure the rights of Personal Data Subjects as regulated under Law No. 27 of 2022 concerning Personal Data Protection (hereinafter referred to as the "UU PDP").

In protecting Personal Data, BNI Ventures establishes this Privacy Notice, which governs the processing of personal data conducted by BNI Ventures in its business activities and operations.

This Privacy Notice constitutes an integral part of the consent you give to our processing of your personal data.

If you do not agree with the terms of this Privacy Notice, you should not use BNI Ventures website or disclose any Personal Data to BNI Ventures.

This Privacy Notice contains the following provisions:

Definitions
In this Privacy Notice, the following terms are defined as:
1. Affiliate refers to any entity, whether established or not, and whether controlled by or controlling a party, where “control” (or any variation thereof) means the ability, directly or indirectly, to direct the affairs of another party, whether through ownership, contract, or otherwise.
2. Personal Data refers to data about an individual who is identified or can be identified either separately or in combination with other information, whether directly or indirectly, through electronic or non-electronic systems, as regulated in this Privacy Notice.
3. Partnership Relationship refers to a legal relationship between the Company and one or more parties to achieve a specific purpose, including but not limited to procurement, collaboration, etc.
4. Venture Capital Business refers to financing activities through equity participation for a certain period for the purpose of business development in the Business Partner.
5. Other Person refers to an individual who is associated with you and to whom Personal Data is attached.
6. Business Partner refers to a business entity that receives investment/equity participation and/or receives participation through convertible bonds from BNI Ventures.
7. Consent to the Use of Personal Data refers to the consent provided by you, either electronically or non-electronically, whether explicitly stated or through actions that indicate consent, which forms an integral part of this Privacy Notice.
8. Personal Data Subject refers to an individual to whom Personal Data is attached, as regulated in this Privacy Notice.

Processing of Personal Data
The processing of Personal Data by BNI Ventures is carried out only based on:
1. Your consent as outlined in the Consent to the Use of Personal Data;
2. Fulfillment of contractual obligations where the Personal Data Subject is a party, or to meet the request of the Personal Data Subject when entering into an agreement;
3. Fulfillment of BNI Ventures’ legal obligations in accordance with the applicable laws and regulations;
4. Fulfillment of the vital interests (related to survival) of the Personal Data Subject;
5. Performance of duties in the public interest, public services, or execution of BNI Ventures' authority under laws and regulations; and/or
6. Fulfillment of other legitimate interests, considering the purposes, needs, and balance between BNI Ventures' interests and the rights of the Personal Data Subject.

Acquisition and Collection of Personal Data
1. BNI Ventures does not collect Personal Data randomly but based on requests.
2. Personal Data acquired and collected by BNI Ventures is done adequately and not excessively, and is intended for the purposes outlined in section 4, which includes but is not limited to:
  1. Personal identification data, which may include full name, place and date of birth, gender, nationality, religion, marital status, home address, phone number, blood type, photo, National Identification Number (NIK), other identity verification numbers, Tax Identification Number (NPWP), Family Card number, biometric data, and/or email address.
  2. Family data up to the first degree, both horizontally and vertically, which may include the spouse's name, children's names, National Identification Number (NIK), other identity verification numbers, gender, place and date of birth, religion, education, nationality, and/or marital status.
  3. Financial data, which may include account numbers, Social Security Administrator Numbers (BPJS), salary data, remuneration data, credit data, and/or tax data.
  4. Personal-related data, which may include health examination results, health information, criminal/violation records, educational background, and/or employment history.
3. If you disclose the Personal Data of Other Persons, you represent and warrant that you have obtained the necessary consent from those individuals to disclose and share their Personal Data with BNI Ventures and to allow BNI Ventures to process their Personal Data in accordance with this Privacy Notice and applicable laws and regulations.
4. By disclosing the Personal Data of Other Persons to BNI Ventures, you also consent to BNI Ventures processing the Personal Data of those individuals in accordance with this Privacy Notice and applicable laws and regulations. Your consent is deemed to be given through this Privacy Notice, and separate consent is not required unless otherwise specified by BNI Ventures.
5. BNI Ventures reserves the right to request that you, when disclosing the Personal Data of Other Persons, provide written proof of consent from those individuals. If you are unable to provide such proof, BNI Ventures has the right not to process the Personal Data of those individuals, not to process your Personal Data, and/or to terminate any legal relationship with you. The absence of a request for proof of consent by BNI Ventures does not waive your responsibility as outlined in sections 3.c and 3.d.
6. You are required to ensure that the Personal Data disclosed to BNI Ventures is correct, accurate, complete, and up to date.
Processing and Analysis of Personal Data
BNI Ventures processes and analyzes Personal Data for the following purposes:
1. Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Prevention of the Proliferation of Weapons of Mass Destruction (PPPSM) assessments related to Venture Capital activities;
2. Reception and management of databases for job applicants and interns;
3. Employee management;
4. Execution of Partnership Relationships; and/or
5. Management of the BNI Ventures website;
  (hereinafter referred to as the "Purposes").
Retention of Personal Data
1. Unless otherwise stipulated by applicable laws and regulations, BNI Ventures will retain the collected Personal Data until:
  1. The end of the 5^th year following the termination of the legal relationship, if the purpose of processing the Personal Data is for:
    - Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Prevention of the Proliferation of Weapons of Mass Destruction (PPPSPM) assessments related to Venture Capital activities;
    - Employee management; and
    - Execution of Partnership Relationships.
  2. The end of the 2^nd year after the Personal Data was received by the Company, if the purpose of processing the Personal Data is for:
    - Reception and management of databases for job applicants and interns; and
    - Management of the BNI Ventures website.
2. The retention of Personal Data by BNI Ventures may be in electronic or non-electronic form.
3. BNI Ventures may store Personal Data in data centers or locations reasonably and properly managed by BNI Ventures or by service providers on behalf of BNI Ventures, either within or outside the country.
4. In cases where the storage of Personal Data is carried out by service providers, BNI Ventures will take reasonably necessary steps to ensure that the Personal Data remains subject to a level of protection comparable to if it were stored by BNI Ventures or to the protection obligations under Indonesian law.
Correction and Update of Personal Data
1. You have the right to correct or update Personal Data, including the Personal Data of Other Persons, that has been disclosed to BNI Ventures, if there are changes to the data from what was last disclosed to BNI Ventures.
2. BNI Ventures is not responsible for automatically correcting or updating your Personal Data or the Personal Data of Other Persons. Therefore, if there is any processing of incorrect, incomplete, or inaccurate Personal Data by BNI Ventures, the responsibility and liability lie with you.
3. You should contact BNI Ventures by submitting a written request through the channels listed in the Communication, Questions, and Complaints section if you wish to correct or update Personal Data, whether it is your Personal Data or that of Other Persons.
Disclosure of Personal Data to Third Parties
1. In cases where, in BNI Ventures' consideration, the disclosure and use of Personal Data to and by third parties is required or necessary for the purposes of achieving the Objectives, you give your consent to BNI Ventures to disclose and use Personal Data to and by the following parties:
  1. Affiliates of BNI Ventures;
  2. Third parties collaborating with BNI Ventures or the Affiliates of third parties;
  3. Third parties whose services are used by BNI Ventures or the Affiliates of third parties; and/or
  4. Regulators, judicial bodies, and authorized institutions in accordance with the provisions of applicable laws and regulations.
2. BNI Ventures will only provide the Personal Data necessary for the purpose of achieving BNI Ventures' Objectives.
3. BNI Ventures will take reasonably necessary steps to ensure that Personal Data is handled securely. If Personal Data is disclosed and used inside or outside Indonesia, BNI Ventures will make reasonable efforts to ensure that the Personal Data receives at least the same level of protection as provided under Indonesian law.
4. With respect to the Personal Data of Other Persons, you represent and warrant that you have obtained the necessary consent from those individuals regarding the disclosure and use as referred to in section 7.a.
5. BNI Ventures reserves the right to request that you provide written proof of consent from those individuals. If you are unable to provide such written proof, BNI Ventures has the right not to process the Personal Data of those individuals, not to process your Personal Data, and/or to terminate any legal relationship with you. The absence of a request for proof of consent by BNI Ventures does not exempt you from the responsibility referred to in section 7.d.
Deletion and Destruction of Personal Data
1. BNI Ventures will delete and destroy Personal Data after the retention period as specified in this Privacy Notice has ended.
2. If it is relevant, you have the right to request the deletion and destruction of Personal Data that has been disclosed to BNI Ventures by submitting a written request to BNI Ventures through the channels listed in the Communication, Questions, and Complaints section.
3. When deleting and destroying Personal Data, BNI Ventures will take reasonable steps to ensure the data is destroyed, erased, and made practically unrecoverable. The specific method of deletion and destruction will depend on the type of Personal Data being destroyed, as well as how it was collected and stored.
Exercise of Personal Data Subject Rights
1. The rights of Personal Data Subjects include:
  1. Obtaining information on the processing of Personal Data;
  2. Completing, updating, and/or correcting errors and/or inaccuracies in Personal Data in accordance with the Objectives;
  3. Accessing and obtaining copies of Personal Data;
  4. Terminating processing, and/or deleting and destroying Personal Data;
  5. Withdrawing consent for the processing of Personal Data;
  6. Objecting to Automated Decision-Making that results in legal consequences/ significant impacts on the Personal Data Subject;
  7. Suspending or restricting the processing of Personal Data proportionally;
  8. Filing a lawsuit for violations in the processing of Personal Data and receiving compensation based on a court decision that has permanent legal force; and/or
  9. Using and/or transmitting Personal Data to other parties if the systems used can securely communicate in accordance with the principles of personal data protection under the Personal Data Protection Law (UU PDP).
2. To exercise the rights of Personal Data Subjects, you may submit a request by sending a written application to BNI Ventures through the channels listed in the Communication, Questions, and Complaints section by using this form. The exercise of certain rights may have consequences on the processing, so we will confirm your request. The exercise of Personal Data Subject rights may not be fulfilled if exceptions to these rights are permitted by the UU PDP. Furthermore, we will make every effort to fulfill your rights and/or provide confirmation or responses to your requests within the time frame stipulated by the UU PDP, which is no later than 3x24 hours after we receive the complete request.
3. Any exercise of the rights of Personal Data Subjects regarding alleged violations in the processing of Personal Data must be submitted in writing to BNI Ventures in accordance with the terms and conditions required by applicable laws and regulations, to be executed and/or responded to by BNI Ventures within no later than 3x24 hours (three times twenty-four hours) or another period allowed by the UU PDP and/or applicable civil procedural law, starting from when BNI Ventures receives a compensation request from the Personal Data Subject, with the Central Jakarta District Court selected as the venue for dispute resolution.
4. In the event of unauthorized access and illegal activities concerning the confidentiality of Personal Data beyond the control of BNI Ventures, BNI Ventures will promptly notify the Personal Data Subject at the earliest opportunity, so that the Personal Data Subject can take steps to mitigate the risks arising from such incidents.
Personal Data Security
BNI Ventures is committed to reasonably ensuring that the Personal Data of the Personal Data Subject obtained by BNI Ventures remains secure during the processing of Personal Data (and throughout the Retention Period). To implement this commitment, BNI Ventures has established procedures and uses electronic systems equipped with an adequate level of security, as required by the Personal Data Protection Law (UU PDP).
Communication, Questions, and Complaints
Any requests, questions, or complaints submitted to BNI Ventures in connection with the implementation of this Privacy Notice must be addressed to:
PT BNI Modal Ventura
Menara BNI Lantai 2
Jalan Pejompongan Raya No. 7
Jakarta Pusat 10210
Changes to the Privacy Notice
This Privacy Notice may be amended and/or updated as needed from time to time. BNI Ventures encourages you to read carefully and check this Privacy Notice periodically to stay informed about any changes to it.
Governing Law
This Privacy Notice is subject to Indonesian law.

By agreeing to this Privacy Notice, you acknowledge that you have read and understood it and agree to all its provisions. In particular, you consent and give permission to BNI Ventures to process your Personal Data in accordance with this Privacy Notice.