Bina Privacy Policy

PT Bank INA Perdana Tbk (hereinafter referred to as “Bank INA“) is fully aware that Personal Data is the most important asset for you, so Bank INA is committed to maintaining the confidentiality and protect your Personal Data, related to the use of banking products and/or services offered by Bank INA.

Bank INA implements policies and best practices aimed at maintaining the privacy and security of your Personal Data in accordance with the Personal Data Protection Act, for data processing activities related to the use of Bank INA’s banking products and/or services (hereinafter referred to as the “Privacy Policy“).

Furthermore, this Privacy Policy applies to all owners of Personal Data (Personal Data Subjects), related to the use of Bank INA’s banking products and/or services.

1. Scope

This Privacy Policy regulates the policies and practices implemented by Bank INA as the Controller of Personal Data in obtaining and collecting, processing and analyzing, storing, correcting and updating, displaying, announcing, transferring, disseminating or disclosing, deleting and destroying (hereinafter referred to as “Processing”) your Personal Data, related to the use of banking products and/or services, includes:

1. Banking services, including Deposits, Loans, Digital Services, and other Banking Services, including but not limited to investment products, Internet Banking, Mobile Banking, and others.

2. Website, email, telephone, features, applications, social media, or other forms of communication provided or used by Bank INA. All services are hereinafter referred to as the “Services“.

2. Definitions

Account is your unique account to access Bank INA products and services.
Cookies and caches are small files with information that your browser or app stores on your device. The information in this file is typically shared with site or app owners in addition to potential partners and third parties. The collection of this information may be used in the functionality of the site and/or to improve your experience.
Personal Data is data about an individual person that is identified or can be identified separately or with other information either directly or indirectly through electronic or non-electronic systems.
Applicable law means the Personal Data Protection Law No. 27 of 2022, and its implementing regulations as amended from time to time and other relevant laws and regulations related to Personal Data Protection.

3. Collection of Personal Data and Use of Information

Collection activities carried out in Bank INA services include but are not limited to:

a. Personal Data Processed by Bank INA

Bank INA collects and uses your Personal Data with your consent to be transferred, managed, and to be used for research purposes to develop and further improve Bank INA’s services, as well as gain further understanding of how Bank INA can improve those services. The use of your Personal Data includes the following:

To be used for the purpose of managing Bank INA’s products, and/or services, including profiling and scoring, to improve service quality and to support Bank INA’s risk management.
To be used for promo offerings and special third-party programs for products and services that are of interest.
For Marketing Purposes and/or Product/Service offerings to be used by Bank INA and/or any other companies within the Salim Group as well as any third parties involved with Bank INA, for products and/or services that may be of interest.
To comply with any relevant legal and regulatory requirements as well as fulfill any request from the regulator, law enforcement, and other legal bodies.

b. How Your Personal Data will be Used

To be used for the purpose of managing Bank INA’s products, and/or services, including profiling and scoring, to improve service quality and to support Bank INA’s risk management.
To be used for promo offerings and special third-party programs for products and services that are of interest.
For Marketing Purposes and/or Product/Service offerings to be used by Bank INA and/or any other companies within the Salim Group as well as any third parties involved with Bank INA, for products and/or services that may be of interest.
To comply with any relevant legal and regulatory requirements as well as fulfill any request from the regulator, law enforcement, and other legal bodies.

c. With whom your Personal Data will be Shared or Disclosed

In connection with the above purposes, with your consent, Bank INA may share your Personal Data with third parties in accordance with the cooperation agreement, including the following parties:

Employees, consultants, temporary workers;
Payment Service Providers, who process your payments on the Website and App;
Logistics providers, such as courier services that will deliver your order to you;
Business partners who separately manage accounts with you for loyalty programs or point redemption (if applicable);
Business partners or vendors in connection with the processing of any promotions, events or services organized by Bank INA (if any);
Professional advisors and consultants;
Agents, contractors, or service providers who provide operational services to Bank INA, such as providers of email, online cloud storage and processing, marketing optimization, information technology, telecommunications, backup and disaster recovery services, security, or other related services that require the collection, use or disclosure of your Personal Data; and
Any other party that you authorize Bank INA to disclose your Personal Data.
Bank INA also uses Google Analytics to help Bank INA understand how Bank INA customers use this site. You can read more about how Google uses your Personal Data here: https://policies.google.com/privacy?hl=en.

4. Your Rights to Your Personal Data

a. Right to Access

Bank INA is committed to fulfilling the right of Personal Data Subjects to access Personal Data collected and processed by Bank INA. In fulfilling a request for access to Personal Data, Bank INA may refuse the request if Bank INA finds that the request for Personal Data meets one or more of the following conditions:

Compromise the security or physical or mental health of the Personal Data Owner and/or any other person.
Impact on the disclosure of Personal Data belonging to others.
Contrary to national defense and security interests.

For further information related to Personal Data access requests, you may contact the communication channels designated by Bank INA.

b. Right to Update/Correction

If you find an error in the Personal Data caused by inaccuracies or the need to update the Personal Data, then you can request Bank INA to correct, complete, and/or update its Personal Data under the management of Bank INA, by contacting the communication channels designated by Bank INA.

In the event of inaccuracies in the provision of your Personal Data, Bank INA has the right to terminate services and/or transactions based on Bank INA’s knowledge and consideration.

Bank INA encourages you to take an active role in ensuring the accuracy and updating of your Personal Data.

c. Right to Erasure

In accordance with the applicable laws and regulations or Bank INA data retention policy or upon your request, Bank INA may delete and/or destroy your Personal Data from the system so that the data no longer identifies you, except in the following cases:

If it is necessary to store Personal Data to fulfill legal obligations, obligations to Indonesian banking regulators, future proof purposes, tax, audit, and accounting. Bank INA will submit the Personal Data required during your use of the Bank’s Services or within the period required by applicable laws and regulations.
Personal Data is still in the retention period based on applicable laws and regulations.

Regarding the need to destroy your Personal Data from the system (right to erase), a written request is required submitted to Bank INA so that the Personal Data can be destroyed from Bank INA’s system as long as it does not conflict with the applicable Guidelines for Retention of Archives of Business Entities in the Banking Sector.

d. Right to Restriction of Processing

You have the right to limit how Bank INA handles your Personal Data. In such case, Bank INA will not use your Personal Data for the purpose of marketing products/services from third parties.

e. Right to Object

If the processing of your Personal Data by Bank INA is based on Bank INA’s legitimate interests, you may object to it for reasons related to your circumstances. Bank INA will honor your objection unless Bank INA has compelling legitimate grounds for the processing that outweigh your interests and rights, or if it is necessary to process Personal Data for the establishment, exercise, or defense of legal claims.

f. Exemption of Data Subject Rights

The application of Data Subject rights has exceptions, such as in the case of the need to:

National defense and security;
Law enforcement;
Public interest, including state administration;
Supervision of the financial sector and financial system;
Statistical activities and scientific research of public interest.
Bank INA is committed to maintaining the privacy and protection of your Personal Data by implementing high-security standards, in line with Bank INA’s privacy policy and strict data protection regulations.

5. Withdraw Consent

You may choose to withdraw your consent in relation to the processing of Personal Data, by contacting Bank INA through the communication channels designated by Bank INA, or through other mechanisms prepared by each Bank INA Service.
If you choose not to receive one Service, Bank INA still has the right to send messages related to other Bank INA Services.
Upon receipt of your request to withdraw your consent to the use of Personal Data to receive marketing or promotional materials or communications, Bank INA will make changes within 3×24 hours at the latest in accordance with applicable laws. Prior to the change being made no later than 3×24 hours, you may continue to receive marketing or promotional materials or communications during this period.
Once the consent withdrawal process is completed, Bank INA reserves the right to stop the collection, use, and/or disclosure of your Personal Data, except in cases where Bank INA needs to retain it for compliance, regulatory, or other legal purposes.

6. Security

Bank INA will retain your Personal Data only for the data collection purposes mentioned in point 3.b of this document and to the extent required by Applicable Law.
The location of the computer server is in a secure and controlled environment. The server is also protected from unauthorized access, use, or disclosure.
Reasonable administrative, technical, and physical protection. These efforts are made to protect user data against access, use, modification, and disclosure of personal information that is not in accordance with applicable laws and regulations.
The Personal Data Subject is responsible for maintaining the confidentiality of his/her Personal Data details and shall always maintain and be responsible for the security of the devices used to access INA Bank services.

7. Storage

As a service provider, Bank INA is committed to retaining your Personal Data for as long as you use Bank INA’s services or as long as your account remains active. Bank INA complies with applicable legal provisions in storing and deleting your Personal Data, based on reasons such as:

Personal data is no longer necessary for the purpose for which it was originally collected;
There is no longer a legal obligation requiring the retention of Personal Data;
You have applied for deletion of Personal Data;
You have withdrawn your consent to the processing of Personal Data.

8. User Data Leakage

In terms of web and application security, if the system/application is known to have been compromised or if the user’s personal information has been disclosed to any irrelevant third parties, as a result of external activities, in terms of security attacks or fraud, Bank INA reserves the right to take action in accordance with applicable laws.

9. Children’s Privacy

Bank INA will only process the data of individuals under the age of 18 with valid consent given by the child’s parents and/or guardians as the person in charge of the child in accordance with the provisions of the law.
Bank INA conveys to parents or supervisors to verify the needs of child data processing.

10. Persons with Disabilities

Bank INA processes the personal data of persons with disabilities by communicating and requesting consent from persons with disabilities and/or guardians of persons with disabilities in accordance with the provisions of laws and regulations.

11. Changes or Updates to the Privacy Policy

Bank INA may update this Privacy Policy from time to time. Changes to the Privacy Policy are effective immediately upon posting of the changes on this page.
This Privacy Policy may be amended and/or updated as needed. Bank INA urges you to always read carefully and check this page periodically for changes to this policy.

12. Cookies Policy

Cookies are text files that are placed on the memory of a user’s device.

a. How Bank INA uses your Cookies and Cache

Bank INA may use cookies and cache to collect, store, and track information for statistical purposes in operating Bank INA websites, applications, and services, as well as to personalize the user experience.

b. How Bank INA controls your Cookies and Cache

You can set your browser to refuse all cookies or to indicate when they are sent. Most browsers have a help feature that will teach you how to accept, disable, or notify you when you receive a new cookie. Bank INA would like to inform you that if you do not accept cookies, you may not be able to use some of the features of its services. Therefore, Bank INA advises you to enable cookies.

13. Consent

As stated above, by registering for or using services on the Bank INA website and application, the user declares:

Consent to Bank INA and/or Bank INA affiliated companies collecting, using, sharing, and/or processing the personal data mentioned above for the purposes described above.
Agree to be bound by this privacy policy when accessing and using Bank INA’s website and application.

The data referred to in this privacy policy will be temporarily stored in the local storage of the user’s gadget in an encrypted manner and will be sent to the server at regular intervals. The data is stored encrypted on Bank INA secure servers and is not shared with the public.

14. Contact Bank INA

If you have any questions about your Personal Data or this Policy, would like to make a complaint regarding the collection, use, or management of your Personal Data by Bank INA, or have questions about Bank INA’s compliance with applicable laws, you may fill in the Personal Data Subject Access Rights Request Form or contact:

Call INA: 1500738 or (021) 30500738

WhatsApp: 0855 1500738

E-mail: bisananya@bankINA.id