Privacy Policy & Cookie Policy

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Chapter 1 — General Provisions

PT CBC Prima ("the Company," "we," "us," or "our") fully recognizes the importance of personal information protection. In compliance with Law No. 27 of 2022 on Personal Data Protection (UU Pelindungan Data Pribadi / UU PDP), the General Data Protection Regulation (GDPR) where applicable, and other relevant laws and regulations, the Company has established this Privacy Policy to ensure the appropriate protection of personal information in its possession.

This Privacy Policy applies to all personal information collected through our website (cbcprima.co.id), our business operations, and any interactions between you and PT CBC Prima.

Definitions

The terms used in this Policy shall have the following meanings:

  • Personal Information — any information relating to an identified or identifiable individual, whether directly or indirectly, through electronic or non-electronic systems.
  • Processing — any operation performed on personal information, including collecting, recording, storing, modifying, disclosing, transferring, distributing, or deleting.
  • Data Controller — PT CBC Prima, as the party that determines the purpose and means of processing personal information.
  • Data Subject — any individual whose personal information is processed by the Company.

Data Controller

PT CBC Prima
Jl. Jend. Sudirman Kav. 10-11, Karet Tengsin, Tanah Abang, Jakarta Pusat 10220, Indonesia
Telephone: (021) 5707590

PT CBC Prima is part of the CBC Group, headquartered at CBC Co., Ltd., 2-15-13 Tsukishima, Chuo-ku, Tokyo 104-0052, Japan. For the Global Network of CBC, please visit: cbc.co.jp/en/

Chapter 2 — Purpose of Use & Data Collection

Types of Personal Information Collected

PT CBC Prima may collect the following types of personal information:

  • Name, company name, job title, and affiliation;
  • Country/region, postal code, address, telephone number, and fax number;
  • Email address;
  • IP address, cookies, and access logs;
  • Information contained in correspondence between you and the Company (emails, telephone conversations, inquiries);
  • Information submitted through forms on our website (contact forms, career applications);
  • CV/resume and related documents submitted for employment purposes; and
  • Other information necessary for providing our products and services.

Purpose of Use

PT CBC Prima will acquire and use personal information through fair and appropriate means, to the extent necessary, for the following purposes:

  • To perform contracts and agreements with customers and business partners, and to provide after-sale services;
  • To receive, process, and respond to inquiries submitted through our website or other channels;
  • To notify business negotiations, meetings, and related communications;
  • To provide information on our products, services, seminars, exhibitions, and other business activities;
  • To analyze customer information for the purpose of improving our products and services, and to collect statistical data;
  • To consider, develop, and launch new products and services;
  • To process job applications and manage recruitment activities;
  • To comply with applicable laws, regulations, and legal obligations; and
  • To achieve the above purposes and related activities, including other purposes clearly stated at the time of acquiring personal information.

In addition, the Company may acquire and use personal information for operations within CBC Group companies that are related to any of the above purposes.

Legal Basis for Processing

Under UU PDP and, where applicable, the GDPR, the Company processes your personal information based on the following legal grounds:

  • Consent — You have given explicit consent for processing your personal data for one or more specific purposes;
  • Contractual necessity — Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract;
  • Legal obligation — Processing is necessary for compliance with a legal obligation to which the Company is subject;
  • Legitimate interest — Processing is necessary for the purposes of legitimate interests pursued by the Company or a third party, provided that such interests are not overridden by your fundamental rights and freedoms.

Chapter 3 — Disclosure, Third Parties & International Transfers

Provision to Third Parties

Unless any of the following situations applies, PT CBC Prima shall not disclose your personal information to any third party without your consent:

  • When you have given prior approval;
  • When disclosure is required by applicable laws and regulations;
  • When it is necessary for protecting human life, personal safety, or property, and obtaining your consent is not feasible;
  • When it is necessary for public health or the healthy development of children, and obtaining your consent is not feasible;
  • When it is necessary for assisting a government agency in performing duties set forth by law, and obtaining your consent may hinder such duties; or
  • When personal information is provided as a result of business succession due to a merger, company split, business transfer, or other corporate restructuring.

PT CBC Prima does not sell personal information to third parties.

Joint Use within CBC Group

Personal information acquired by the Company may be jointly used within the CBC Group for the purposes described in Chapter 2. When personal information is jointly used, reasonable security management measures shall be in place between the Company and joint user companies to safeguard personal information appropriately.

Personal information subject to joint use: Company name, affiliation, job position, name, address, telephone number, email address, and information contained in exchanges between you and the Company.

Joint user companies: CBC Group companies as listed on the CBC Network (cbc.co.jp/en/).

Purpose of joint use: As described in Chapter 2 "Purpose of Use."

Person responsible for managing jointly used personal information: Management of CBC Co., Ltd., 2-15-13 Tsukishima, Chuo-ku, Tokyo 104-0052, Japan.

Transfer to Outside Indonesia

PT CBC Prima may transfer your personal information to countries outside Indonesia, including Japan (CBC Co., Ltd. headquarters) and other countries where CBC Group companies operate.

When transferring your personal information outside Indonesia, the Company shall:

  • Ensure that the receiving country has an adequate level of personal data protection, or that the receiving party has established equivalent safeguards;
  • Obtain your consent for such transfer where required by applicable law;
  • Take necessary and appropriate measures to ensure the continuous protection of your personal information by the receiving party; and
  • Comply with the requirements set forth under UU PDP and, where applicable, the GDPR regarding cross-border data transfers.

For transfers to countries within the European Economic Area (EEA), the Company shall utilize standard data protection clauses or other approved transfer mechanisms as required by the GDPR.

Chapter 4 — Security, Retention & Your Rights

Security Management Measures

PT CBC Prima shall establish an appropriate system for managing personal information in accordance with applicable laws and regulations, and take the following security management measures:

  • Organizational measures — The Company has appointed a person responsible for handling personal information, developed internal regulations concerning safe data handling, and established a system for reporting and addressing any non-compliance.
  • Personal measures — The Company regularly provides data protection training to all employees who handle personal information.
  • Physical measures — The Company implements measures to prevent unauthorized persons from accessing personal information, including restricted access to facilities and secure storage of physical records.
  • Technical measures — The Company has introduced access control systems to limit the scope of authorized personnel, and protects information systems against unauthorized access and malicious software from external sources.
  • External environment — The Company implements security management measures after assessing personal information protection systems in each country where data is stored or processed.

Data Retention

PT CBC Prima retains your personal information for the period necessary to achieve the purposes outlined at the time of collection. The Company may retain personal information for a longer period, taking into consideration the volume, nature, and sensitivity of the information; potential risks of harm from unauthorized use or disclosure; the possibility of achieving purposes through alternative means; and compliance with applicable laws, tax obligations, and business needs.

For job applications, if your application is unsuccessful, we will retain your information for up to 12 months after the conclusion of the recruitment process, unless you request earlier deletion.

Your Rights

Under UU PDP (Indonesia's Personal Data Protection Act) and, where applicable, the GDPR, you have the following rights regarding your personal information:

  • Right to information — You have the right to know how the Company collects, processes, and uses your personal data.
  • Right of access — You have the right to verify whether the Company is processing your personal data and to access that data.
  • Right to correction — You have the right to request correction of inaccurate or incomplete personal data.
  • Right to deletion — You have the right to request deletion of your personal data, subject to legal and legitimate retention requirements.
  • Right to restrict processing — You have the right to request that the Company restricts the processing of your personal data in certain circumstances.
  • Right to object — You have the right to object to the processing of your personal data, including for direct marketing purposes.
  • Right to data portability — You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
  • Right to withdraw consent — Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
  • Right not to be subject to automated decisions — You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects.

To exercise any of these rights, please contact us using the information provided in Chapter 6. The Company shall confirm your identity before responding to any request. We will respond within the timeframe required by applicable law.

Links to Third-Party Websites

Our website may contain links to third-party websites that are not under the control of PT CBC Prima. The Company is not responsible for the privacy practices of such websites. We recommend that you review the privacy policy of each website you visit.

Chapter 5 — Cookie Policy

What Are Cookies?

Cookies are small text files that are placed on your device when you visit a website. They are used to make websites function properly, improve user experience, and provide information to the website operator. Cookies do not directly collect personal information that identifies you.

Types of Cookies We Use

  • Essential Cookies — These cookies are necessary for the basic operation of our website, such as enabling page navigation and access to secure areas. The website cannot function properly without these cookies. No personally identifiable information is stored by essential cookies.
  • Analytics Cookies — These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. This helps us improve the performance and content of our website.
  • Functional Cookies — These cookies enable the website to remember choices you make (such as your language preference) and provide enhanced, personalized features.

Use of Google Analytics

This website uses Google Analytics, a web analytics service provided by Google LLC. Google Analytics uses cookies to help us analyze how visitors use our website.

The information generated by cookies about your use of the website (including your IP address) is transmitted to and stored by Google on servers that may be located outside Indonesia. Google will use this information to evaluate your use of our website, compile reports on website activity, and provide other services related to website activity and internet usage.

The information collected and analyzed by Google Analytics does not contain information that can identify specific individuals. This information is managed by Google LLC in accordance with its own privacy policy.

For more information:

To opt out of being tracked by Google Analytics, you may download and install the Google Analytics Opt-out Browser Add-on from tools.google.com/dlpage/gaoptout.

How to Manage Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to:

  • View what cookies are stored and delete them individually;
  • Block third-party cookies;
  • Block cookies from specific websites;
  • Block all cookies; and
  • Delete all cookies when you close your browser.

Please note that if you disable or block certain cookies, some features of our website may not function properly.

For instructions on managing cookies in popular browsers:

Chapter 6 — Contact & Inquiries

If you wish to make a request regarding disclosure, correction, deletion, restriction of use, or any other matter relating to your personal information, please contact us at:

PT CBC Prima
Jl. Jend. Sudirman Kav. 10-11, Karet Tengsin, Tanah Abang, Jakarta Pusat 10220, Indonesia
Telephone: (021) 5707590

For privacy inquiries, please use our Contact Us page: cbcprima.co.id/contact-us/

The Company shall verify your identity before responding to any request. We will respond by the method you prefer (electronic or written), unless otherwise required by law. If no preferred method is specified, the Company shall choose the appropriate method of response.

Chapter 7 — GDPR Appendix

The following additional provisions apply to individuals who are eligible for protection under the General Data Protection Regulation (GDPR) or the UK Data Protection Act (DPA). If there is any conflict between the provisions of Chapters 1–6 and this Chapter, the provisions of this Chapter shall take precedence for eligible individuals.

Data Controller for EEA/UK

For individuals in the EEA or UK, the data controller is:

CBC Co., Ltd. 2-15-13 Tsukishima, Chuo-ku, Tokyo 104-0052, Japan

PT CBC Prima processes personal data as a processor on behalf of CBC Co., Ltd. where applicable.

Legal Grounds for Processing (GDPR)

CBC shall process your personal data based on the following legal grounds as set forth in Articles 6 and 7 of the GDPR:

  • Such processing is necessary to pursue legitimate interests;
  • Such processing is necessary to perform a contract to which you are a party;
  • Such processing is necessary to comply with legal obligations; and
  • CBC has obtained your prior consent.

Transfer to Third Countries

The Company may transfer personal data acquired in the EEA to third countries, including Indonesia and Japan, in order to perform contracts or take pre-contractual steps at your request. For transfers to countries for which the European Commission has not adopted an adequacy decision, the Company shall utilize standard contractual clauses or other approved transfer mechanisms.

Additional Rights under GDPR

In addition to the rights listed in Chapter 4, individuals in the EEA/UK have the right to:

  • Lodge a complaint — You have the right to file a complaint with the data protection supervisory authority in the EU/EEA member state where your residence or workplace is located, or where an alleged violation of the GDPR has occurred.
  • Object to direct marketing — You have an absolute right to opt out of direct marketing or profiling for direct marketing at any time.

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