Privacy and Customer Personal Data Protection Policy
PT Bank MNC Internasional Tbk (hereinafter referred to as “MNC Bank” or the “Bank”), licensed and supervised by the Financial Services Authority (OJK), headquartered in Central Jakarta and with branch offices spread across the territory of the Republic of Indonesia, understands the importance of maintaining and protecting the security of Customer Personal Data as users of MotionBank services. MNC Bank has drafted this Privacy and Customer Personal Data Protection Policy (hereinafter referred to as the “Privacy Policy”) to explain to the Customer how Personal Data provided by the Customer to MNC Bank is obtained, processed, maintained, used, displayed, transmitted, delivered, deleted, and destroyed when downloading, uploading, accessing, and using MotionBank services, in accordance with Law Number 27 of 2022 concerning Personal Data Protection (hereinafter referred to as the "PDP Law") as well as other relevant and prevailing laws and regulations.
Customers acknowledge that the submission of Personal Data to MNC Bank is done voluntarily. If a Customer is unwilling to provide Personal Data, the Customer understands that MNC Bank will be unable to process said data for the purposes set forth in this Privacy Policy, which may result in MNC Bank’s inability to provide services or products to the Customer or to process the Customer's transactions. It is important for Customers, as users of MotionBank, to read and understand every provision written in this Privacy Policy. Based on the aforementioned points, MNC Bank implements the Privacy Policy as follows:
I. Definition of Personal Data
In this Privacy Policy, "Personal Data" refers to any data, information, and/or descriptions in any form that are attached to and can identify an individual, either directly or indirectly, through electronic or non-electronic systems from time to time.
II. Acquisition and Collection of Personal Data
Provided directly by the Customer for any reason;
Using previous MNC Bank services and/or products;
Registering, accessing services, and conducting transactions through MotionBank;
Giving consent to MNC Bank to collect Personal Data from electronic devices, such as location information and cookie data;
Modifying and/or updating Personal Data;
Requested by MNC Bank (if necessary) from time to time; or
Providing Personal Data to MNC Bank affiliates (“MNC Group”) and/or other third parties who are partners of MNC Bank and have a cooperation agreement with MNC Bank.
As the Personal Data Controller, MNC Bank prioritizes Customer Personal Data and guarantees that it will maintain confidentiality in collecting Personal Data, limited only to the purposes of processing Personal Data as regulated in this Privacy Policy and applicable laws and regulations. MNC Bank collects Customer Personal Data when:
The categories and types of Customer Personal Data that may be processed are as follows:
Personal Profile Identification Data: Including full name, National Identification Number (NIK), gender, nationality, place and date of birth, mother’s maiden name, aliases/nicknames, religion, voice recordings, image recordings, photos, and/or biometric data;
Correspondence Data: Including the address as stated on the Identity Card (KTP), domicile address and status, email address, and telephone/mobile phone numbers;
Education and/or Employment Data: Including education level, occupation type, line of business, job title, division, year of starting work/business, name of the company/institution of employment, workplace address, and employment status;
Family Data: Including marital status, spouse's name, number of children, and number of dependents;
Financial Data: Including account numbers, sources of income, monthly/annual income amount, monthly/annual expenditure amount, transaction data, credit/financing data, investment-related data, asset-related data, collateral-related data, tax data, and data regarding other financial services received by the Customer;
Digital Activity Data: Including the Customer's activities within the Bank’s application and the interaction between the Bank’s application and other applications on the Customer’s electronic device; and/or
Customer Banking Transaction Data on MotionBank; and/or
Other Data that can be classified as Personal Data.
III. Use of Personal Data
MNC Bank may process and/or use Personal Data for the purposes stated below:
To provide, design, and/or develop services, banking facilities, products or services, and statistical analysis—including the use of new technologies and the utilization of MNC Bank services—and to inform the Customer of any changes to the services.
To conduct profiling and scoring of the Customer for service enhancement and the Bank's risk management.
For marketing purposes, namely offering products and/or services, promotions, or information of interest to the Customer, sent by MNC Bank and/or the MNC Group and/or other third parties who are business partners of MNC Bank, via physical mail, email, short message services (SMS), telephone, facsimile, correspondence tools, and other official MNC Bank information delivery media in accordance with and subject to applicable laws and regulations.
For the execution of MNC Bank’s business, involving consultations with professional advisors or the Bank’s external auditors—including legal advisors, financial advisors, and consultants—MNC Group companies, and any party bound by a confidentiality obligation to MNC Bank.
To fulfill Know Your Customer (KYC) requirements or "Know Your Customer" principles, the Bank's risk mitigation efforts, and the verification/authentication of the accuracy of Customer data based on applicable laws and regulations.
To comply with laws, regulations, and orders from regulators, law enforcement officials, and other authorized institutions.
For other purposes in accordance with the Bank's internal policies and provisions, or according to the terms and conditions governing the relationship between the Bank and the Customer, carried out in accordance with applicable laws and regulations.
IV. Personal Data Processing
The Bank may act as the Personal Data Controller to process Customer Personal Data, where the objectives of processing said data include, among others:
Providing and processing Services chosen or held by the Customer, including:
Providing banking services and information related to such services;
Complying with laws and regulations, including the implementation of Customer Due Diligence (CDD) principles and programs for Anti-Money Laundering, Counter-Terrorism Financing, Prevention of Proliferation Financing of Weapons of Mass Destruction, and Anti-Bribery and Corruption policies in connection with the provision of services to the Customer;
Responding to and resolving requests from the Customer regarding the provision of services;
Modifying, enhancing, and/or developing services, including updates and/or adjustments to applications/systems related to the services; and/or
Fulfilling other needs as necessary, provided they relate to the provision/processing of services to the Customer.
Implementing and improving operational activities, and complying with applicable laws and regulations, including:
Conducting surveys, research, and studies related to service provision, including generating analytical data through data analysis and/or usage patterns for research, analysis, testing, product development, and cooperation with third parties;
Collecting payments for the provision of services;
Conducting activities related to accounting, auditing, taxation, and reconciliation concerning the provision of Services, as well as internal administrative processes;
Fulfilling obligations based on agreements with the Customer and/or relevant third parties (including but not limited to vendors and partners);
Preventing, detecting, and investigating any suspicious transactions, criminal acts, or prohibited activities, including those based on applicable laws and regulations;
Communicating with the Customer through various media, including responding to questions, comments, or complaints;
Processing Customer participation in any production activities, contests, games, promotions, polls, or surveys;
Performing other internal activities necessary to provide services, such as software troubleshooting, bug fixes, operational issues, data analysis, testing, and research, and to monitor and analyze usage trends and activities;
Fulfilling requests related to law enforcement and protecting the rights of MNC Bank and/or the Customer;
Fulfilling other needs as necessary in providing services, provided they relate to the implementation/improvement of operational activities and compliance with applicable laws and regulations.
Product offerings and promotions, which include offers for services, products, prize draws, events, or other forms of promotion deemed suitable to the Customer’s needs and profile. MNC Bank may deliver offers for products/services owned or provided by MNC Bank and/or the MNC Group and/or other third parties who are business partners of MNC Bank, through various media and/or methods, both orally and in writing, including push notifications, social media, instant messaging applications (e.g., WhatsApp), SMS, phone calls, email, brochures, and other relevant electronic and non-electronic media in accordance with applicable provisions.
MNC Bank may process Customer Personal Data if instructed or required by authorized government agencies, for purposes stated or regulated under applicable laws and regulations.
The processing of Customer Personal Data may be carried out by third parties; therefore, MNC Bank may share/disclose Customer Personal Data to third parties for further processing in accordance with the purposes and grounds for processing Customer Personal Data by MNC Bank.
V. Customer Rights as Personal Data Subjects
Customers have the following rights as Personal Data Subjects:
The right to obtain information regarding the clear identity of the party requesting the Customer's Personal Data, as well as the purposes of the request and the use of the Customer's Personal Data.
The right to complete, update, and/or correct errors and/or inaccuracies in the Customer's Personal Data in accordance with the purpose of the Personal Data processing. However, MNC Bank cannot accommodate changes to Personal Data if MNC Bank believes that such changes would violate any laws and regulations and/or legal requirements that cause the information to become incorrect.
The right to access and obtain a copy of Personal Data in accordance with the provisions of laws and regulations and MNC Bank's policies in an appropriate or readable format, whereby MNC Bank reserves the right to charge a reasonable fee to fulfill such requests.
The right to terminate processing, delete, and/or destroy Personal Data in accordance with the provisions of laws and regulations. Customers may be unable to use and/or receive MNC Bank services if they choose to delete and/or destroy their Personal Data, whether in part or in its entirety. MNC Bank's obligation to delete and destroy Customer Personal Data is waived in the following cases:
National defense and security interests;
Law enforcement processes;
Public interests related to state administration;
Supervision of the financial services sector, monetary policy, payment systems, and financial system stability;
Statistical and scientific research purposes;
Compliance with applicable laws (e.g., Customer Due Diligence (CDD) or crime prevention);
If the request is irrelevant to the Bank’s processing activities or the data subject;
If it endangers the physical or mental health/safety of the data subject or others; and/or
If it impacts the disclosure of another person’s Personal Data.
The right to withdraw consent for the processing of Customer Personal Data previously granted to MNC Bank. The Customer is deemed to have understood and accepted the consequences of withdrawing consent for the processing of Personal Data.
The right to object to the results of the processing of Customer Personal Data that produce legal consequences or have a significant impact on the Customer.
Right to Delay or Restrict Processing: The right to proportionately delay or restrict the processing of the Customer’s Personal Data in accordance with the purpose of said processing. However, the Customer must understand that a request to delay or restrict processing may affect MNC Bank’s ability to provide products or services to the Customer, as well as the contractual relationships established between MNC Bank and the Customer or between MNC Bank and other third parties; this includes the potential suspension of services received by the Customer and/or the termination of one or more of the Customer’s agreements with MNC Bank and/or a breach of one or more of the Customer’s obligations under agreements with MNC Bank.
Other rights in accordance with laws and regulations regarding the processing of Customer Personal Data, to the extent provided for under the prevailing laws and regulations.
VI. Storage and Deletion or Destruction of Personal Data
MNC Bank ensures that Personal Data submitted by the Customer will be stored securely in accordance with MNC Bank's internal policies and the laws and regulations prevailing in the Republic of Indonesia. MNC Bank will retain the Customer's Personal Data for as long as necessary to fulfill the purposes set forth in this Privacy Policy, as required to meet MNC Bank’s obligations to the Customer, to protect or defend the interests of MNC Bank and its Customers, or as mandated by applicable law.
To the extent that it does not conflict with prevailing laws and regulations, MNC Bank will cease storage and immediately delete and/or destroy the Customer's Personal Data once the processing of said data is no longer deemed necessary based on the purposes outlined in this Privacy Policy.
The deletion or destruction of Customer Personal Data at MNC Bank may be carried out in accordance with the following provisions:
The purpose of processing the Customer's Personal Data has been achieved and the Personal Data will not be reused in accordance with the Bank's retention policy or the provisions of laws and regulations governing such matters; or
Upon the Customer's request, unless otherwise specified by the prevailing laws and regulations.
VII. Disclosure of Personal Data
MNC Bank understands the need to comply with the provisions of this Privacy Policy and will continue to maintain its confidentiality; however, for the purposes set forth in this Privacy Policy, the Customer understands that MNC Bank reserves the right to provide the Customer's information to third parties under the following conditions:
Permitted or consented to by the Customer;
Required, mandated, or necessary to maintain MNC Bank’s compliance with the provisions of prevailing laws and regulations.
VIII. Withdrawal of Consent
To the extent that it does not conflict with prevailing laws and regulations, the Customer has the right to withdraw or revoke consent, either in part or in its entirety, for the provision of Personal Data. This request may be submitted to the Bank in writing via email to: cs@motionbank.id. Depending on the circumstances and the nature of the consent being withdrawn or revoked, this may result in MNC Bank being unable to provide services to the Customer. Upon receiving the Customer's notice to withdraw or revoke consent, MNC Bank will inform the Customer of the potential consequences of such withdrawal so that the Customer may decide whether they still wish to proceed.
IX. Limitations
The Customer understands that the following situations are considered beyond the control of MNC Bank:
An act of nature or unforeseen circumstances that result in the damage or destruction of equipment and/or systems used to secure, store, or process the Customer's Personal Data;
Personal Data that was already available to or discoverable by the public before it was submitted to MNC Bank;
Situations where MNC Bank has exercised its best efforts to verify, secure, and protect Personal Data, yet unauthorized access, hacking, misuse, modification, alteration, or interference still occurs;
The accuracy (except for Personal Data verified by MNC Bank at its discretion), validity, legality, and completeness of the Customer's Personal Data; and/or
Misuse of Personal Data and information caused by criminal acts, fraud, or any illegal activities, or the wrongful actions of a third party not under the control or instruction of MNC Bank.
X. Contact Us
Should there be any questions or matters that require clarification, the Customer may contact the MNC Bank Call Center at 1500188 or send an email to: customer_care@mncbank.co.id
XI. Policy Changes
MNC Bank may amend, supplement, and/or replace this Privacy Policy from time to time (with notice to the Customer) to ensure that this Privacy Policy remains aligned with the procedures and practices implemented by MNC Bank in processing Customer Personal Data, as well as to comply with the provisions of prevailing laws and regulations.
XII. Miscellaneous
This Privacy Policy is governed by and construed in accordance with the laws of the Republic of Indonesia.
This Privacy Policy has been harmonized with the provisions of prevailing laws and regulations, including the regulations of the Financial Services Authority (OJK).
By using MNC Bank services, the Customer acknowledges that they have read and understood this Privacy Policy and grants consent for the processing of Personal Data in accordance with this Privacy Policy.
