Privacy Notice

PT Link Net Tbk (referred to as "Link Net", "us" or "we" or "our") is committed to protecting personal data of our customers, business partners, visitors, employment candidates and/or employees and personal data of individuals who work for, or act on behalf of, our customers and/or business partners (collectively, "data subject") that has been provided to us. In Link Net, we take privacy seriously and all our activities are underpinned by our T.R.U.S.T principles of being Transparent, respecting your Rights, in our Use of your personal data, through robust cyber Security practices and we take due care when Transfer of data is required.

This privacy notice (“Privacy Notice”) explains what and how personal data is collected and further processed by us, for what purposes it is collected and further processed by us, sources (if any) of personal data, to whom personal data is disclosed and how to access and update your personal data and where to go for further information in respect of the personal data.

If you provide us with personal data of other individuals, you hereby represent that you have obtained consent from that individual prior to providing their personal data to us. References to ‘your personal data’ in this Privacy Notice would include such individuals personal data that you provide to us.

We may from time to time amend, modify, vary or update this Privacy Notice and you are bound by such modifications, variations or updates.

Information about children

If you are under the age of 18, it is your obligation to obtain the consent of your parent or legal guardian before sending us your personal data (for example, your name, address and email address).

Information on disability

If you are a person with a disability guardian needed, then you are obliged to obtain consent from your legal guardian before sending us your personal data (for example, your name, address and email address).

What personal data do we collect from you?

The types of personal data information that we can collect include, but are not limited to:

1. For Customers
   • contact information (such as name, address, e-mail address and telephone number, etc.);
   • identification information (such as National Identification Number (KTP), Passport Identification Number, Taxpayer Identification Number (NPWP), Driver’s License Number (SIM), date of birth, etc.);
   • demographic information (such as age range, marital status, gender, nationality, etc.);
   • photographs, such as those that you may submit for contests or prize-winning competitions;
   • banking information (such as direct debit and related bill payment banking transactions);
   • any recordings captured through our communication platform(s) (such as telephone recordings, Microsoft Teams, Zoom, etc.);
   • any footage captured or recorded by our surveillance camera (CCTV) system;
   • biometrics and facial recognition as the application uses it and consented by the customer;
   • geographic location information, such as the location derived from your IP address or GPS, Base Station, Bluetooth or Wi-Fi signals, satellites, telecommunication towers and information about how you engage with and use our Services, for example when you choose to activate the service location-enabled on the device you use to access the service;
   • We collect information from and about various technologies in which Our Services are used. The type of information collected depends on technology, usage, and device and personal settings. Examples of this technology could be computers, phones and tablets, as well as devices that can be used in interactive, connected technologies in homes or other vehicles.
2. For Business Partners and Suppliers
   • contact information (such as name, address, email address and telephone number, etc.);
   • identification information (such as National Identification Number (KTP), Passport Identification Number, Taxpayer Identification Number (NPWP), Driver’s License Number (SIM), date of birth, etc.);
   • business information (such as name of organisation, job title, department, business address, organisation structure, shareholding, directorship, etc.);
   • any recordings captured through our communication platform(s) (such as telephone recordings, Microsoft Teams, Zoom, etc.);
   • details contained in business registration documents, third-party due diligence documents, trade references and credit checks;
   • financial details including banking account details and bank account statements;
   • any footage captured or recorded by our surveillance camera (CCTV) system;
3. For Visitor to Any of Our Premises or Events
   • contact information (such as name, address, email address and telephone number, etc.);
   • identification information (such as National Identification Number (KTP), Passport Identification Number, Taxpayer Identification Number (NPWP), Driver’s License Number (SIM), date of birth, etc.);
   • business information (such as name of organisation, job title, department, business address, etc.);
   • race;
   • nationality;
   • reason for visit;
   • date and time of visit;
   • photograph;
   • biometrics and facial recognition;
   • security notes (special instructions and access restrictions);
   • any footage captured or recorded by our surveillance camera (CCTV) system;
4. For Applicants, Candidates and Beneficiaries
   • contact information (such as name, address, email address, telephone number, etc.);
   • identification information (such as National Identity Number (KTP), Family Card (KK), Passport Number, Taxpayer Identification Number (NPWP), or Social Security Administration Agency Number (BPJS), Driving License (SIM), date of birth, etc.);
   • academic and professional information (such as field of studies, university, country of study, academic scores and achievements, professional qualifications and certifications, etc.);
   • employment information (such as previous job title, previous job location(s), employment period, etc.);
   • biometrics and facial recognition;
   • demographic information (such as age range, marital status, gender, nationality, etc.);
   • emergency contact information (such as name, address, telephone number, e-mail address, etc.);
   • beneficiary/next-of-kin;
   • financial information (such as beneficiaries’ incomes, bank account name and number, etc.);
   • photograph(s);
   • video footage(s) submitted to us (such as profile pictures, contest submissions, etc.);
   • any footage captured or recorded by our surveillance camera (CCTV) system;

Additional sensitive personal data that we may collect:

• additional employment history (such as performance and disciplinary record, medical, hospitalisation and annual leave record, salary details);
• result of your health test(s), if any;
• philosophical and political views or affiliations;
• religious belief;
• sexual orientation;
• criminal record.

Additional sensitive/spesific personal data that we may collect

We may, during times of crisis such as war, terrorism, riots, natural disaster or health crisis/disease outbreak, collect:

• health and physical condition;
• health condition of individuals in your household;
• result of your health test(s), if any;
• whether you are or were in self-isolation when you are or were unwell;
• body temperature;
• political views or affiliations.

When do we collect your personal data?

We may collect or obtain your personal data:

1. For Customers
   • when you use our network, products and/or services (including through our call centres, dealers, and sales channels);
   • when you contact us or register for information relating to our network, products and/or services or for any other purposes(s);
   • when you communicate with us (such as SMS, text messages or other digital channels, emails, questionnaires or surveys);
   • when you use or interact with any of our digital applications, visit any of our websites or social media pages;
   • when you participate in any of our promotional events, incentives or loyal programs;
   • from external agencies (such as credit reference agencies, screening or investigation agencies);
   • from our internal database pursuant to your relationship with any member of our group of companies;
   • from our surveillance camera (CCTV) system.
2. For Business Partners and Suppliers
   • when you use our network, products and/or services;
   • when you communicate with us (such as SMS, text messages or other digital channels, emails, questionnaires or surveys);
   • when you use or interact with any of our digital applications, visit any of our websites or social media pages;
   • from external agencies (such as credit reference agencies, screening or investigation agencies);
   • from our internal database pursuant to your relationship with any member of our group of companies;
   • from our surveillance camera (CCTV) system.
3. For Visitors
   • when you complete our visitor log book or visitor entry form;
   • when you provide us with your identification document(s);
   • when you provide your host with information;
   • from our surveillance camera (CCTV) system.
4. For Employment Candidates and Employees
   • when you make an application to us;
   • when you communicate with us (such as SMS, text messages or other digital channels, emails, questionnaires or surveys);
   • from external agencies (such as credit reference agencies, screening or investigation agencies);
   • from your referee;
   • from your previous employer(s);
   • from anyone with whom you may have or had a business relationship with;
   • from your or our recruiter, recruitment agency or recruitment website/platform;
   • from your health and physical advisor (such as doctor and dentist);
   • from our internal database pursuant to your relationship with any member of our group of companies;
   • from our surveillance camera (CCTV) system.

How do we uses your personal data

Your personal data may be collected, used or processed by us for, among other things, the following purposes:

1. For Customers
   • providing you with our products, services and/or offers which may be of interest to you;
   • notifying you about benefits and changes to the features of our products and services;
   • providing you with our latest offers, campaigns and promotions (where you subscribe to such updates);
   • sending you service messages about our subscription or account registration;
   • using your data for participation in our customer surveys or meetings;
   • compliance with laws and legal, contractual and/or regulatory obligations protecting or exercising our legal, contractual and/or regulatory rights and remedies;
   • sending you information via telephone calls, text messages or other digital channels, emails, etc. or social media about products and services offered by selected third parties that we think may interest you;
   • other legitimate purposes.
2. For Business Partners and Suppliers
   • business execution;
   • organisation and management of the business;
   • health, safety and security;
   • compliance with laws and legal, contractual and/or regulatory obligations protecting or exercising our legal, contractual and/or regulatory rights and remedies;
   • protecting our assets and interests;
   • other legitimate purposes.
3. For Visitors
   • health, safety and security;
   • compliance with laws and legal, contractual and/or regulatory obligations protecting or exercising our legal, contractual and/or regulatory rights and remedies;
   • other legitimate purposes.
4. For Employment Candidates
   • identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
   • record keeping in relation to recruiting and hiring;
   • conducting background checks, as permitted by applicable law;
   • compliance with laws and legal, contractual and/or regulatory obligations protecting or exercising our legal, contractual and/or regulatory rights and remedies;
   • contacting you or your emergency contact in emergency situations where the health or safety of one or more individuals may be endangered;
   • other legitimate purposes.

5. For Employees

   (in addition to the purposes set out for Employment Candidates above)

   • career progression and personal development;
   • administration and management of salary and employment benefits;
   • short term and long-term incentive plan;
   • employment and industrial relations disputes, including but not limited to litigation;
   • corporate exercises undertaken by members of our group of companies;
   • management of performance;
   • application of work permits and immigration requirements;
   • loans, insurance and medical purposes;
   • disciplinary actions or terminations;
   • ensure health and safety in the workplace;
   • accounting, financial reporting and business planning;
   • security monitoring purposes;
   • organize team-building activities and other business related events;
   • internal or external investigations;
   • research, salary surveys and for audit purpose;
   • to comply with reasons as stated in your contract of employment with us;
   • in relation to any legal or regulatory request or demand.

Who do we disclose your personal data to?

We may disclose your personal data:

1. For Customers
   • to members of our group companies;
   • to third parties when disclosure is necessary or reasonable to protect our rights, protect your security, investigate fraud or respond to a law enforcement request;
   • to our service providers, field engineers, contractors, subcontractors or any other third party performing work on our behalf or at our instruction;
   • to our business partners for our marketing activities;
   • to third parties for credit checks and fraud management;
   • to third parties for carrying out analytics to understand how you use our services;
   • to third parties for research and development purposes;
   • to third parties for the purposes set out under “How do we use your personal data?”.
2. For Business Partners and Suppliers
   • to members of our group companies;
   • to our third party agents, service providers, consultants, advisors, contractors and/or subcontractors;
   • to any public authority, governmental, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which we are subjected to or as permitted by applicable local law;
   • to third parties for the purposes set out under “How do we use your personal data?”.

3. For Visitors

   We do not routinely share/transfer your personal data with any external organizations or third parties. However, where and whenever we share/transfer your personal data, it shall be for the purposes set out under “How do we use your personal data?” and we shall do so in accordance with applicable data privacy laws, unless required or permitted by law.

4. For Employment Candidates and Employees
   • to members of our group companies;
   • to any regulatory or governmental authority or authorized bodies having jurisdiction over us or any member of our group of companies;
   • to background verification providers;
   • to any regulatory or governmental authority or authorized bodies having jurisdiction over us or any member of our group of companies;
   • to third party payroll processors;
   • to any third-party organizations involved in any corporate exercises undertaken by us or any member of our group of companies;
   • to third parties for the purposes set out under “How do we use your personal data?”.

We use reasonable efforts in accordance with industry best practices to ensure that the above mentioned maintain the confidentiality of your personal data and are restricted from using your personal data for any unauthorised purpose.

Transfers of Personal Data Across Data Borders

We may transfer your personal data across geographical borders to other entities. Where your personal data has been transferred to members of our group of companies and/or to third parties located outside of Indonesia, the transfer of your personal data is carried out under organizational, contractual and legal measures and with adequate levels of protection implemented as well as any additional local legal requirements for the parties receiving this information in order to safeguard your personal data.

How do we store and protect your personal data?

We may collect and store your personal data in electronic or physical form, depending upon the requirement. Information may be stored at our and third-party premises within IT Systems (e.g. external cloud storage, internal or third party management systems, e-mail, database, hard drives), document warehouses etc.

We endeavour, where practicable, to process your personal data in a safe environment by preventing any unauthorized or unlawful processing of personal data or accidental loss or destruction of, or damage to, such information. We have implemented various physical, technical and administrative security measures to protect your personal data and our network from unauthorized access. Some of these measures include:

• encryption of data in transit or at rest;
• strict adherence to privacy and security practices;
• periodic security assessment and reviews to upgrade our practices;
• restriction of access to such data to personnel who have a need to know such data.

How long do we retain your personal data?

We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or b) a shorter period where the individual objects to the processing of their personal data.

Exercise Your Rights

We respect your rights and privacy and we live up to our position by taking steps to ensure that your personal data is accurate and up-to-date. In compliance with Personal Data Protection Law No. 27 Year 2022, we assure you that:

• You have the right to know what personal data we have about you;
• You have the right to request a copy of your personal data;
• You have the right to correct your personal data to ensure it is accurate, complete and up-to-date;
• You have the right to withdraw your consent from our processing of your personal data;
• You can also ask us to restrict how we use your personal data where it is likely to cause damage or distress;
• You have the right to prevent processing of your personal data for purposes of direct marketing;
• You have the right to request exercise data portability.

To exercise your rights, you can contact us in the ways listed in the “Contact Us” section listed below.

You may request us to stop sending our communications to you by contacting us on the below mentioned contact details. These choices do not apply to the receipt of mandatory product or service communications that are considered as part of certain Link Net products or services, which you may receive periodically, unless you cancel the subscription of our products or services.

Consequences arising from failure to provide Personal Data

You can access our website without providing your personal data. However, if every activity/service on our website/weblink requires us to collect certain personal data about you, failure to provide such information can:

• result in us being unable to process your application and/or provide you with our services;
• causes us to be unable to respond to your requests for our products/services;
• restrict or prevent access to certain features on our websites/weblinks;
• as a result we are unable to provide you with the latest information regarding any promotions or launches of our services/products;
• resulting in your inability to accept invitations to promotional activities that we organize;
• negatively affect our ability to communicate with you;
• result in our ability to enter into a contract with you or a counter-party or continuing to contract with you or a counter-party;
• negatively impact your chances of being selected for any potential employment, engagement or internship.

Merger & Acquisition

We may disclose your personal information as part of a planned or actual corporate transaction such as a reorganization, merger (merger), sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets or stock (including in connection with bankruptcy or similar proceedings).

By providing us with your personal data, you agree that:

• You have read and understand this Privacy Notice and agree to the use of your personal data as set out in this Privacy Notice.
• All information and representation provided are true and correct to the best of your knowledge, and you have not knowingly omitted any relevant information which may have an adverse effect.

Contact us

If you have any questions or complaints about this notice, our privacy and information handling practices, or would like to exercise your rights as data subjects, please contact us at enterprise.inquiry@linknet.co.id for Enterprise Customer, contact@firstmedia.com for Media Customer, supplier.helpdesk@linknet.co.id for business partners and suppliers, or recruitment@linknet.co.id for employment candidates and employee, kindly reach out to our Data Privacy Officer at dpo@linknet.co.id.

Dispute resolution

In cases of alleged/actual violations of your privacy, in relation to your information that we process or hold, you may lodge a complaint with the relevant regulatory authority or other court/court of competent jurisdiction.

Update to Privacy Notice

We reserve the right to amend, modify, vary or update this Privacy Notice, at our sole discretion from time to time, as and when the need arises. The most recently published Privacy Notice shall prevail over any of its previous versions. We have no obligation to inform you of any variations and you are encouraged to check this Privacy Notice from time to time to stay informed of any changes. You agree to adhere to the terms of the Privacy Notice including any variations.

Version information

This Privacy Notice was last updated in June 2025.