This Privacy Policy is a real commitment from PT Kalbe Farma Tbk and its affiliates (hereinafter referred to as "Kalbe" or "We") to respect and protect any data or personal information of every individual who interacts with Kalbe's services and/or activities ("Data Subject" or “you”).

This Privacy Policy regulates the acquisition, collection, processing, analysis, storage, repair and updating, display, announcement, transfer, dissemination, disclosure, deletion and/or destruction, related to data or information that Data Subjects provide to Kalbe. Our data acquisition and collection is carried out both online and offline, including personal data that we collect through our various channels, including but not limited to the Kalbe Site, consumer relationship management, points of sale, events, programs, surveys, etc. (hereinafter referred to as as “Data”).

By agreeing to this Privacy Policy, you declare that any Data is correct and valid Data. By agreeing to the Privacy Policy, you are also deemed to have read and understood our Privacy Policy and Terms and Conditions.

A. Data Acquisition and Collection

Kalbe collects Data for purposes including but not limited to managing and expediting processes for customer relationship and service management, contests, marketing, promotions, managing and expediting service processes, as well as other purposes as long as permitted by applicable laws and regulations.

The data collected is as follows:

Data submitted independently by the Data Subject, including but not limited to Data submitted when the Data Subject:

Create or update an account via the Kalbe Site, including but not limited to name, e-mail address, family information, telephone or mobile number (if any), password, photo, and/or other information;

Uploading personal data of Data Subjects in connection with Kalbe services, including but not limited to name, e-mail address, telephone or cellphone number, family information (for example: number of children), health history, products consumed by the Data Subject and/or family, as well as other personal data, uploaded by the Data Subject;

In connection with Kalbe's consumer relationship management program, this program aims to establish long-term relationships with consumers, including sending regular newsletters, gifts, information about new products, conducting surveys, creating profiles, etc.;

Data Subject Call to Kalbe Customer Service (Kalbe Customer Service or "CS KN"). Communications with CS KN can be recorded or listened to, in accordance with applicable laws and regulations, for operational needs (for example for quality, training and follow-up purposes by us). You will be notified of the recording at the start of your call;

Fill out surveys sent by Kalbe or on behalf of Kalbe;

Using features that require access permission to the Data Subject's device; and/or

Other data submitted through third party services in connection with Kalbe services and/or programs.

Data recorded when a Data Subject uses the Kalbe Site, including but not limited to:

Data in the form of the time of each Data Subject's activities, including but not limited to registration activities, logins, use of services on the Kalbe Site, and other data;

Usage data or Data Subject preferences, including Data Subject interactions in using the Kalbe Site, saved choices, and selected settings. Such data is obtained using, including but not limited to, cookies, pixel tags, and similar technologies that create and maintain unique identifiers;

Device data, including the type of device used to access the Kalbe Site, including but not limited to hardware model, operating system and version, software, file name and version, language options, unique device identifier, advertising identifier, serial number, movement information device, and/or mobile network information, as well as other additional data required by reference to the browser access request on the Data Subject's device; and/or

Record data (log), including records on the server that receives data such as device IP address, date and time of access, features or pages viewed, Kalbe Site work processes and other system activities, browser type, and/or Kalbe Site or third party services that Users use before interacting with the Kalbe Site.

Data obtained from other sources, including but not limited to:

Third parties who help Kalbe in developing and presenting services on the Kalbe Site to Data Subjects, including but not limited to Product Purchase service providers and/or other partners;

Third parties used by Data Subjects to create or access Kalbe accounts, including but not limited to social media services, or Kalbe Sites or applications that use Kalbe's Application Programming Interface (API) or that Kalbe uses;

Marketing service providers; and/or

Generally available sources.

Kalbe can combine and/or process Data obtained from these sources with other Data it owns.

B. Data Usage

Kalbe may use all or part of the Data obtained and collected from Data Subjects as mentioned in the previous section for the following matters:

With the Data Subject's consent (if required), We use the Data Subject's Personal Data (i) to analyze the Data Subject's preferences and habits, (ii) to anticipate the Data Subject's needs based on Our analysis of the Data Subject's profile; and/or (iii) to display targeted content and advertisements. Based on this type of information, and with the consent of the Data Subject (if required), we also display special Kalbe content or promotions that are tailored to the interests of the Data Subject.

For our business purposes, including but not limited to, analyzing and managing our business, market research, auditing, developing new products, improving our products and services, identifying usage trends.

Process all forms of requests, submissions, activities or actions carried out by Data Subjects in connection with Kalbe's services and/or activities.

Providing features to provide, realize, maintain, and/or improve products and/or services, including but not limited to:

Offer, obtain, provide, or facilitate services or other products through the Kalbe Site; and/or

Carrying out internal activities necessary to provide services on the Kalbe Site, including but not limited to solving software problems, bugs, operational problems, conducting data analysis, testing, research, and/or to monitor and analyze usage trends and activities of Data Subjects.

Assisting Data Subjects when communicating using Kalbe services, including to:

Check and resolve Data Subject problems and/or problems;

Direct the Data Subject's questions to the appropriate service personnel to resolve the problem; and/or

Monitor and/or improve service responses.

Contacting Data Subjects via e-mail address, letter, telephone, mobile phone (if any), and/or other communication channels, including but not limited to assisting and/or processing the resolution of problems and/or problems experienced by Data Subjects regarding services and/ or Kalbe activities.

Use information obtained from Data Subjects for research, analysis, development and/or testing purposes to improve the security and comfort of Kalbe's services and/or activities, as well as developing new features and/or services.

Inform Data Subjects regarding features, services, promotions, studies, surveys, news, latest developments, events, and/or other matters. Kalbe can also use this information to promote and process promos, provide prizes, and present relevant advertising and/or content about services provided by Kalbe and/or its business partners.

Contacting Data Subjects in the context of Consumer Relationship Management and Consumer Service programs, including but not limited to sending routine newsletters, gifts, information about new products, conducting surveys, creating profiles, consumer service purposes, including answering questions from Data Subjects. This usually requires the use of certain personal contact information and information regarding the reason for the Data Subject's inquiry (e.g. order status, technical problems, product complaints/questions, general inquiries, etc.).

Monitoring or investigating activities, activities or transactions that are suspicious (if any) and/or that are indicated to contain elements of fraud or violations of the Terms and Conditions or applicable laws and regulations, as well as taking the necessary actions as a follow-up to the the results of monitoring or investigations into such activities, activities or transactions.

Kalbe may use features provided by third parties in order to improve Kalbe's services and/or content, including but not limited to customizing and serving advertisements to each Data Subject based on interests or visit history. If the Data Subject does not want advertisements to be displayed based on these adjustments, then the Data Subject can set this via the browser.

Kalbe in certain circumstances, if necessary to use or disclose Data Subject Data for law enforcement purposes or to fulfill legal requirements and applicable laws and regulations, including in the event of a dispute or legal process between the Data Subject and Kalbe.

C. Storage of Personal Data

We will store and use your Personal Data for the period necessary to fulfill the purposes for collecting Personal Data as described in point B and/or to comply with applicable legal requirements. Personal data will be retained for the period permitted by applicable laws and regulations.

About how long we store information about you depends on how long the data processing will take place with us. After a certain time, We will delete or anonymize your information, or if this is not possible (for example, because the information has been stored in backup archives), then We will securely store your information and isolate it from further use until deletion is possible.

D. Disclosure and Transfer of Personal Data

Your Personal Data will be processed by our authorized staff or agents, based on information needs, depending on the purpose of obtaining and collecting your personal data.

We may need to transfer your personal data to our affiliates (Kalbe Group) and to third parties, in connection with the purposes set out in this Privacy Policy. For this reason, We may transfer your personal data to other countries that may have data protection compliance requirements and laws that differ from those applicable in the country where you are located.

Kalbe guarantees that there will be no disclosure of Data to any party, without permission from the Data Subject, except in the following cases:

It is necessary to disclose Data to third parties who assist Kalbe in processing the Data.

It is necessary to disclose data to third parties who assist Kalbe in providing services on the Kalbe Site and process all forms of Data Subject activities on the Kalbe Site.

Kalbe may provide relevant information to vendors, legal consultants, financial consultants, external auditors, marketing partners, research firms, similar service providers, and/or other third parties, including but not limited to marketing activities carried out by Kalbe or on behalf of Kalbe through a third party.

Data Subjects contact Kalbe through public media such as blogs, social media, and/or certain features on the Kalbe Site, where communications between Data Subjects and Kalbe may be publicly visible.

Kalbe may share Data Subject information with its subsidiaries and/or affiliates to help provide/provide services or carry out Data processing for and on behalf of Kalbe.

Kalbe discloses Data Subject Data in an effort to comply with legal obligations and/or valid requests from law enforcement officials and/or authorized government agencies/institutions.

E. Children's Personal Data

We may obtain personal data from children under 18 years of age with the express consent of their parents or guardians directly who are Data Subjects.

F. Cookies

Cookies are small files that will automatically be placed on the Data Subject's device and carry out the function of storing the Data Subject's preferences and configuration while visiting a Kalbe Site or application.

Data Subjects can determine the choice to accept, reject, and/or delete Cookies when using the Kalbe Site (this choice may limit optimal service when accessing the Kalbe Site).

G. Data Subject Rights

Mobile devices in general (iOS, Android, and so on) have settings so that the Kalbe Site cannot access certain Data without the consent of the Data Subject. The mobile device will provide notification to the Data Subject when the Kalbe Site first requests access to the Data.

To the extent permitted by applicable provisions, Data Subjects can contact Kalbe to withdraw consent to the acquisition, collection, storage, management and/or use of Data. If this happens, the Data Subject understands the consequences that the Data Subject will not be able to use the services on the Kalbe Site.

Data Subjects have the right to submit a request to Kalbe to:

accessing his personal data (right of access).

Data Subjects may submit a request to obtain a copy of personal data relating to them that is stored or processed by Kalbe.

update or correct errors and/or inaccuracies in his personal data (right of rectification).

Data Subjects can submit requests to replace or correct errors and/or inaccuracies in their personal data.

delete or/or destroy personal data belonging to the Data Subject (right of erasure).

Data Subjects may submit a request for deletion of their personal data. Please note that there is some personal data that is essential for Kalbe in the context of security and providing the best experience for Data Subjects.

delay or limit the processing of personal data proportionally in accordance with the purposes of personal data processing (right of restriction of processing).

Data Subjects can submit a request to postpone or limit the processing of their personal data, so that the processing is carried out within the limits of the initial data processing purposes that they are aware of and agree to.

use and send his Personal Data to other Personal Data Controllers (right of data portability).

Data Subjects can submit a request to obtain a copy of their personal data in a common format and ask Kalbe to transfer their personal data to another Personal Data Controller as long as the other Personal Data Controller's system has collaborated with Kalbe.

raise an objection (right to object).

Data Subjects can submit requests regarding objections to the processing of their personal data which is used for direct marketing, fulfilling the obligations of personal data controllers in public services in the public interest, and/or fulfilling other legitimate interests by taking into account the objectives, needs and balance of interests of the personal data controller and rights of personal data owners.

raise objections to decision-making actions that are only based on automatic processing regarding a person's profile ( profiling) (right to object to automated decision making & profiling).

Data Subjects can submit requests regarding objections to the automated processing of their personal data which gives rise to legal consequences or has a significant impact on the Data Subject.

Data Subjects have the right to request a copy of the Data Subject's information, to object to the use of the Data Subject's information, to request deletion or restriction of the Data Subject's information, or to request the Data Subject's information in a structured and electronic format. Data Subjects can send notifications to Kalbe Customer Email. The Data Subject will receive notification and/or confirmation of the status of this request.

However, the Data Subject's requests and choices may be limited in certain cases, for example, if fulfilling the Data Subject's request would reveal other people's information, or if the Data Subject requests to delete information where We are legally permitted or there is a legitimate reason to retain it. In addition, we will continue to process and share when required by law and statutory regulations, including but not limited to:

If personal information is required pursuant to a court request;

If the collection and processing is necessary in the performance of or in connection with a contract or between the Data Subject, Us, including but not limited to, the Data Subject's continued use of Us; And

Personal Information is collected or processed as a result of legal obligations on our part.

H. Deletion of Information

Kalbe will continue to store the Data until a request for withdrawal of consent or deletion of information regarding the Data is made by the Data Subject.

Kalbe will delete Data Subject Data in accordance with the provisions of applicable laws and regulations.

I. Privacy Policy Updates

Kalbe may make changes or updates to this Privacy Policy at any time. Kalbe recommends that Data Subjects read carefully and check this Privacy Policy page from time to time for any changes. By continuing to access and use Kalbe services and other Kalbe site services, the Data Subject is deemed to have agreed to the changes in this Privacy Policy.

J. Miscellaneous

This Privacy Policy was created and regulated in accordance with applicable laws in the Republic of Indonesia.

All disputes or differences of opinion arising from the implementation of this Privacy Policy will first be discussed and resolved by Kalbe and the Data Subject by deliberation to reach a consensus, and if deliberation to reach a consensus is still not reached, then Kalbe and the Data Subject agree and agree to resolve it through court in accordance with the legal jurisdiction of Kalbe.

The headings in this Privacy Policy are made for reference only, and in no way define, limit, explain or describe what is contained in each of these sections.

This Privacy Policy is only made in Indonesian, which will bind Kalbe and the Data Subject.

Note: This Privacy Policy is effective November 25, 2022