GENERAL PRIVACY STATEMENT

This General Privacy Statement (also referred to as our "Privacy Statement") explains how PT Asix Indonesia Cerdas, and our subsidiaries and affiliated companies ("Asix," "we," "our," or "us") collect, use, share and otherwise process information that identifies or could be identifiable to you ("personal data" or "personal information").

1. SCOPE & RESPONSIBILITY

This General Privacy Statement explains your rights and choices related to the personal data we collect when:

• You visit, interact with or use any of our websites, social media pages, marketing or sales communications, or register for our products and services ("Online Properties"); and
• You visit, interact with or use any of our offices, events, sales, marketing and other offline activities ("Offline Properties") (collectively, the "Properties");

This General Privacy Statement does not cover:

• Automatic collection from our products and services: This Statement does not cover the information we automatically collect in connection with your use of Asix products and services.
• Applicant Information: This Statement does not cover information related to our employment recruiting efforts.
• Customer Content: Certain Asix products permit customers to ingest or upload and submit content to the products ("Customer Content"). This notice does not cover Customer Content, including any personal data about you that may be contained in Customer Content, because the Customer, rather than Asix, controls how Customer Content is processed. Any questions about the processing of Customer Content should be addressed to the Customer directly.
• Organizational Use: When you use our products or services on behalf of an organization (e.g., your employer), your use is administered and provisioned by your organization under its policies regarding the use and protection of personal data. If you have questions about how your data is being accessed or used by your organization, please refer to your organization's privacy policy and direct your inquiries to your organization's system administrator.

2. INFORMATION WE COLLECT & HOW WE COLLECT IT

Asix collects personal data and other information from you directly, through automated means, and from third parties. More information on each category follows:

• From You

We collect personal data when you voluntarily provide it to us (including to our service providers or other parties who collect it on our behalf). For example, we collect personal data when you order, register to use, or request information about Asix products and services, subscribe to marketing communications, complete surveys, provide such data in product feedback, or sign up for an Asix event or webinar. We may also collect personal data from you when you attend one of our events, during phone calls with sales representatives, or when you contact customer support.

The personal data we collect may include contact information (such as your name, address, telephone number, or email address), professional information (such as your employer name, address, job title, department or job role), user IDs, and passwords, and contact preferences. We collect information you choose to provide when completing any "free text" boxes in our forms (for example, for event sign-up, product feedback, or survey requests), and we collect personal data disclosed by you on message boards, chat features, blogs, and other services or platforms to which you can post information and materials (including third party services and platforms).

• From Third-Party Sources

We may also acquire data from other sources including affiliates in our corporate group, our partners, or others that we use to make our information better or more useful.

3. HOW WE USE THE INFORMATION

Depending on the situation, we may use your information for the following purposes:

• Communications and Transaction Processing. We use your information to communicate with you, respond to your requests, and provide the information you requested. We also use personal data, including financial, credit card, and payment information, to process transactions.
• Advertising. We use your information to provide personalized advertising to you per your privacy preferences settings and applicable law. We might also share some of your information with marketing service providers and digital marketing networks to present advertisements that might interest you.
• Business Operations. We use your information to conduct ordinary business operations, e.g., business research and analytics, corporate reporting and management, staff training and quality assurance purposes, and outreach.
• Security. We use the information to maintain the integrity and security of our websites, products and services and preventing and detecting security threats, fraud, or other criminal or malicious activity that might compromise your information or the information of other customers or website visitors.
• Third Party Social Networks. We may use personal data to interact with you on third party social networks.
• Conferences and Events. Asix and our partners may use your information to communicate with you about our events or our partner events. After the event, Asix may contact you about the event and related products and services. We may share information about your attendance with your company, and our conference sponsors and partners, where legally permitted to do so. If a partner or conference sponsor directly requests your personal data at their conference booths or presentations, your information will be handled per their privacy practices. We recommend that you review the privacy practices of such partners and sponsors.
• Research & Innovation. We use your information to develop new products, features, and services using research and development tools and incorporating data analysis activities.
• Comply with Law. We use your information as required to be compliant with applicable laws, regulations, court orders, government, and law enforcement requests.
• Other Legitimate Business Purposes. We may use your information when it is necessary for other legitimate purposes, such as protecting Asix's confidential and proprietary information.

4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We only use your personal data in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, we rely on the following legal bases:

• As necessary to prepare and enter into a contract;
• Consistent with specific revocable consents;
• As necessary to comply with our legal obligations;
• To protect your vital interests or those of others; and
• As necessary for our (or others') legitimate interests, including our interests in, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data.

 

5. YOUR PRIVACY RIGHTS

Depending on where you live, you may have certain rights such as:

• Access: To request and obtain a copy of your personal data that is held by Asix;
• Rectification: To request the correction of your personal data held by Asix in order to update any incomplete or inaccurate information;
• Deletion: To request to have your personal data held by Asix deleted;
• Restrict Processing: To request that we restrict the processing of your personal data where:

• You dispute the accuracy of the data;
• The processing is unlawful, but you do not wish to have it delete; or
• Asix no longer needs the data, but you need it to assert, exercise, or defend legal claims.

• Objection: To object to the further processing of your personal data at any time;
• Portability: To request to receive the personal data you have provided to Asix in a structured, commonly used, machine-readable format; and
• Withdrawal of consent: To request to withdraw consent at any time, where previously given.

If your personal data is to be used for a new purpose that is materially different from that for which it was originally collected or subsequently authorized, or is disclosed to a non-agent third party in a manner that is not specified in this Statement, we will provide you with an opportunity to choose whether to have your personal data used or disclosed in such a manner.

Certain personal data, such as information about medical or health conditions, racial or ethnic origin, and religious or political beliefs may be considered "Sensitive Personal Data." Asix will not process Sensitive Personal Data for a purpose other than for the purpose it was originally collected or subsequently authorized unless we have received your affirmative and explicit consent.

6. SECURITY

Asix is committed to protecting the security of personal data. We use appropriate technical and organizational measures to protect personal data from unauthorized access, use, or disclosure. Despite these measures, Asix cannot eliminate security risks associated with personal data, and mistakes and security breaches may happen. We retain the data only as required or permitted by law, and while the data continues to have a legitimate business purpose.

7. OTHER INFORMATION

Data Retention. We retain information collected in connection with the Properties for so long as necessary to fulfill the purposes outlined in this Statement or where we have an ongoing legitimate business need to do so.

Changes to this Privacy Statement. This General Privacy Statement is subject to occasional revision. If we make any substantial changes in the way we use personal data, we will take appropriate measures to inform our customers, consistent with the significance of the changes we make. We will provide notice of any material changes if and where required by applicable data protection laws.

Last Revised: January 2025